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Non-resident trusts
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27. The Principal Act is amended in Chapter 3 of Part 19—
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(a) in section 579 by substituting the following for subsection (6):
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“(6) This section shall not apply—
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(a) in relation to a loss accruing to the trustees of the settlement, or
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(b) where it is shown to the satisfaction of the Revenue Commissioners that the settlement was established for bona fide commercial reasons and did not form part of an arrangement of which the main purpose or one of the main purposes was the avoidance of liability to capital gains tax.”,
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and
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(b) in section 579A by inserting the following after subsection (9):
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“(9A) This section shall not apply where it is shown to the satisfaction of the Revenue Commissioners that the settlement was established for bona fide commercial reasons and did not form part of an arrangement of which the main purpose or one of the main purposes was the avoidance of liability to capital gains tax.”.
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