This section provides that where the income of a non-resident individual includes an amount in respect of a distribution out of export relieved profits, the distribution is to be treated for purposes of tax at the higher rates as representing an amount of income equal to the unrelieved amount under section 66.

He loses it?

Yes. The non-resident will not get the tax credit. It would be unfair to tax him as if he had got it. Where the distribution is out of relieved profits he would get a reduction of that relief.

Why? Is it because he is a non-resident?

Yes.

Will he get the credit eventually?

No. He will not get tax credit but he will not be taxed on it either.

There will be no dividend if he is tax free.

Why is he not getting the export relief if his money is being invested in an Irish exporting company?

Remember that under the double taxation agreements that exist between ourselves and Britain relief will be forthcoming.

But he will not get the export relief. I do not see why we should deprive him of the benefit since he has his money in an Irish company.

We are simply providing that if he does not get the tax credit he will not be taxed as if he did receive it.