Finance Act 2015

Amendment of section 590 of Principal Act (attribution to participators of chargeable gains accruing to non-resident company)

39. Section 590(7) of the Principal Act is amended by inserting the following after paragraph (a):

“(aa) a chargeable gain accruing on the disposal of assets where it is shown to the satisfaction of the Revenue Commissioners that the disposal was made 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 or corporation tax,”.