Revenue Note for Guidance

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Revenue Note for Guidance

Section 88B Funds: reorganisation

This section provides for an exemption from stamp duty on any instrument made for the purposes of a scheme of reconstruction or amalgamation under which

(a) a foreign fund transfers its assets to a domestic fund in return for the domestic fund issuing units in the domestic fund to the holders of units in the foreign fund or directly to the foreign fund, or

(b) a domestic fund transfers its assets to a foreign fund in return for the foreign fund issuing units in the foreign fund to the holders of units in the domestic fund or directly to the domestic fund.

A domestic fund is an investment undertaking within the meaning of section 739B of the Taxes Consolidation Act 1997 other than a Common Contractual Fund referred to in section 739I(1)(a)(ii) of that Act. The exemption applies to instruments executed on or after 31 March 2006.

Relevant Date: Finance Act 2014