Capital Distribution on Group Restructuring
16/12/1994
Query
Does a charge under S.583 TCA 1997 arise?
Decision
Where a capital distribution is generated purely by an internal group restructuring undertaken for bona fide purposes, no charge under S.583 TCA 1997 will be imposed.
Capital Gains Tax
Section 583, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:G.132(F)