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Notwithstanding any other provision of the Tax Acts or the Capital Gains Tax Acts, sections 631 to 634 sections 631, 632, 633, 633A, 633C and 634 shall not apply as respects a transfer or disposal unless it is shown that the transfer or disposal, as the case may be as respects a transfer, disposal or the formation of an SE or an SCE by merger unless it is shown that the transfer, disposal or merger, as the case may be , is effected for bona fide commercial reasons and does not form part of any arrangement or scheme of which the main purpose or one of the main purposes is avoidance of liability to income tax, corporation tax or capital gains tax.

(2) Where section 631, 632, 633 or 634 section 631, 632, 633, 633A, 633B, 633C or 634 applies in relation to a transfer or disposal, the transferring company shall make a return of the transfer or disposal, as the case may be, to the appropriate inspector in such form as the Revenue Commissioners may require.