The Government has published a revised version of the bill establishing the National Assets Management Agency (NAMA). The bill provides for a series of amendments to Irish tax legislation, most notable; exemption from tax on income and gains arising to NAMA, and the introduction of section 396C to deal with the treatment of losses.
Measures contained in the bill ensure that income and gains arising to NAMA will be exempt from income tax, corporation tax and capital gains tax. NAMA will also be exempt from stamp duty for all headings under Sch 1 of the Stamp Acts.
The bill modifies loss relief available for participating banks and provides that the amount of the available loss which may be set against trading income in the current year is restricted to 50%. Group loss relief may be claimed subject to certain conditions contained in the bill.
The revised bill is available on the Oireachtas website here.