Revenue E-Brief Issue 116/18, 28 May 2018
Tax and Duty Manual Part 20-01-04 (Transfers of assets, other than trading stock, within group) has been updated to reflect the amendment made to Section 617 TCA 1997 by Section 31 Finance Act 2017.
This amendment extended the meaning of a group of companies for the purposes of the relief to companies that are resident for tax purposes in countries with which this country has a double taxation treaty.
The manual has also been amended to clarify that the relief can apply to transfers between members of a group of companies arising from mergers and divisions under the Companies Act 2014, provided the conditions of Section 617 are met.
28 May 2018