I am advised by the Revenue Commissioners that since the previous tax exemption scheme for stallion stud fee income ended in July 2008, stallions are treated as stock-in-trade. This means that where the owner (including a part owner) of a stallion is carrying on the trade of farming, any profits or gains arising in respect of stallion stud services are treated as if they arise in the course of the farming trade and are charged to tax as part of the profits of that trade. Otherwise, profits or gains arising in respect of stallion stud services are charged to tax under Case IV of Schedule D.
For Irish tax purposes "farming" means farming farm land, that is, land in the State which is wholly or mainly occupied for husbandry, other than market garden land. Subject to the provisions of the double taxation agreements in force between the State and other countries and of the Taxes Consolidation Act 1997, companies or individuals who are resident for tax purposes in the State are chargeable to tax here on worldwide profits or gains while companies or individuals who are non-resident in the State are chargeable to tax here only on profits or gains arising in the State. If the Deputy has more specific information on this issue, he might forward details to the Revenue Commissioners so that they can investigate the matter.