Since 1 January 2003, corporate income has been characterised into two distinct streams: trading or active income which is taxed at the 12.5% corporation tax rate and non-trading or passive income which is taxed at the 25% corporation tax rate.  Since that date, the distinction between a company’s activities (i.e. whether the activities constitute trading activities or whether they constitute passive activities) is an important one, as the Irish Revenue Commissioners (“Revenue”) are cognisant of and will prevent low substance businesses (otherwise known as “brass plate operations”) availing of the lower rate.