Revenue Note for Guidance

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Revenue Note for Guidance

600M Relief

Summary

Section 600M provides relief on the gains arising from the disposal of a qualifying investment by a qualifying investor by applying a reduced rate of Capital Gains Tax (CGT) to a portion of those gains.

Details

(1)Relief under this section will be available to a qualifying investor who disposes of a qualifying investment in a qualifying company, except for certain disposals.

(1)(a)A qualifying investor who disposes of a qualifying investment in a qualifying company shall be entitled to claim relief under this section.

(1)(b)Relief is not available where the disposal—

  1. (b)(i)constitutes the redemption, repayment or repurchase of eligible shares by the company, or
  2. (b)(ii)is a part disposal of eligible shares.

(2)The amount of gain to which the relief is available is the lower of—

  1. (2)(a)the chargeable gain,
  2. (2)(b)twice the amount of the qualifying investment in the eligible shares disposed of, or
  3. (2)(c)the balance of the lifetime threshold available to the individual which is €10 million.

This restriction of twice the gain on the investment is the prescribed limit under Article 21a of GBER which restricts the benefit an individual investor may obtain under GBER.

(3)The reduced rate of CGT is 16% where the investment is made directly in the company by an individual.

(4)A lifetime limit may apply to gains under this section.

(4)(a)The lifetime limit is €10 million.

(4)(b)Where the individual makes several sales in a year to which the relief is available, relief is treated as available on the earlier disposals in priority to the later sales.

(5)The information that is to be provided by an individual when making a claim for the relief includes—

  1. (5)(a)the name and address of the qualifying company that issued the shares;
  2. (5)(b)the date on which the investment was made;
  3. (5)(c)the value and number of shares subscribed;
  4. (5)(d)the identification number of the certificate of commercial innovation assigned by the Revenue Commissioners.

Relevant Date: Finance Act 2024