Revenue Precedent

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Revenue Precedents

Investment by Lloyds syndicates, some of whose members are resident in Ireland for tax purposes would not prejudice the tax exempt status of the fund as Lloyds syndicates are regarded as non-resident investors and there is no look through to the individual Lloyds “names”. 5019/96

The take-over of a foreign fund, with Irish resident investors, by an SCIU would not prejudice the tax exempt status of the SCIU provided the Irish investors are removed from the fund within 3 months of the date of the take-over. 2577/93

The holding of units by an Irish resident nominee company on behalf of non-residents would not prejudice the exempt status of the SCIU provided the nominee company is in the business of holding shares in a nominee capacity and advance approval is received from the Revenue Commissioners. 1579/89