Irish Revenue Clarifies Classification of Foreign Entities for the Purpose of CGT Group Relief and Exemption on Disposal of Shares

Irish Revenue has issued eBrief No. 135/26 concerning updates to Tax and Duty Manual Part 20-01-04 (Transfers of assets, other than trading stock, within a group (S.617)), which provides guidance on the operation of Capital Gains Tax (CGT) group relief provisions on the transfer of assets within a group, as provided for in section 617 of the Taxes Consolidation Act 1997 (TCA 1997). The CGT group relief provisions allow a company to transfer chargeable assets (other than trading stock) to an…