On 3 September 2015, Ireland Revenue announced in eBrief No. 82/15 that it will challenge the use of capital gains tax relief for certain reorganizations if used to avoid tax on ultimate disposals. The text of the eBrief is as follows:

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It has come to the attention of Revenue that section 615, Taxes Consolidation Act (TCA) 1997, which provides relief from Capital Gains Tax (CGT) on a trans…