Taxes Consolidation Act, 1997 (Number 39 of 1997) 1039Restrictions on chargeability. [ITA67 s205] (1) Nothing in this Chapter shall render a non-resident person chargeable in the name of— (a) a broker or general commission agent, or (b) an agent, not being— (i) an authorised person carrying on the regular agency of the non-resident person, or (ii) a person chargeable as if that person were an agent in pursuance of this Chapter, in respect of profits or gains arising from sales or transactions carried out through such a broker or agent. (2) The fact that a non-resident person executes sales or carries out transactions with other non-residents in circumstances which would make that person chargeable in pursuance of this Chapter in the name of a resident person shall not of itself make that person chargeable in respect of profits arising from those sales or transactions.