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

620 Replacement of business assets by members of group


This section modifies “rollover relief” (under section 597) in the context of groups of companies. Section 597 provides for rollover relief where a person disposes of trading assets and uses the proceeds to acquire other trading assets within a given period. Under the rules, the person may claim that the chargeable gain on the old assets is not charged to tax until the person disposes of the replacement assets. This section provides that for the purposes of section 597 all trades carried on by members of a group of companies are to be treated as a single trade.


(1) See section 597 for the meanings of “old assets” and “new assets”.

(2) All trades “to which the section applies” are to be treated as a single trade for the purposes of “rollover relief” under section 597.

(3) The trades to which the section applies are trades carried on by resident companies and trades carried on in the State through a branch or agency by companies not resident in the State (but which are resident in other EU Member States or in EEA Member States with which Ireland has a tax treaty – as provided for in the definition of “company” in section 616).

(4) In the case of companies which are not resident in the State the assets concerned must be chargeable assets in relation to the company if this section is to apply.

Relevant Date: Finance Act 2021