Revenue Note for Guidance

The content shown on this page is a Note for Guidance produced by the Irish Revenue Commissioners. To view the section of legislation to which the Note for Guidance applies, click the link below:

Revenue Note for Guidance

582 Calls on shares

Shares of a nominal value may sometimes be issued at par but only a proportion of the cost of the shares may be paid up at the date of issue of the shares, the balance not being due to be paid up until the company calls on the shareholders to pay the balance. Section 582 provides that where the cost price of shares or debentures of a company is not fully paid up at the time of issue, and a call is made more than 12 months later, indexation under section 566 is to be applied to the cost of the call on the shares or debentures only from the date of payment of the call.

If the call took place before 6 April, 1974, section 582 does not apply as the shares are normally treated under section 566 as having been acquired on that date for their market value on that date, which value reflects the call made on the shares. Also, section 582 does not apply to calls on shares or debentures within 12 months of original issue in order to exclude the common case of payment for shares by way of a part payment on application followed some weeks or months latter by a payment on allotment.


A applies for 1000 €5 shares in a company on 1 January, 2002. The payment on application for the shares was €1 per share, that is, €1,000, and on allotment on 1 April, 2002 €3 per share, that is, €3,000. The shares were thus issued as €5 shares (€4 paid up), that is, the base cost is €4,000. On there was a call on the shares of €1 per share and A paid over €1,000. On 1 September 2009 A sold the shares for €8 each, that is, €8,000.

Computation of chargeable gain —

Sale proceeds


Less deductible expenditure

€4,000 (paid in 2002) × 1.171 =



€1,000 (paid in 2005) × 1.081 =





Relevant Date: Finance Act 2021