Disposal of Shares/Options

24/06/1991

Query

Where an individual disposes of shares in a company on the take-over of that company within the three year "relevant period", would the relief be withdrawn by virtue of this section?

Decision

Yes

Income Tax

Section 498 (3), Taxes Consolidation Act, 1997

Origin: Direct Taxes International and Administration

File ref:3584/87C


27/05/1992

Query

Would the existance of a CAP on dividends and assets on a winding up, and a put-call option offend this rule?

Decision

No. The existence of a CAP would not necessarily preclude the granting of approval but its bearing on other aspects of the case would need to be examined.

Income Tax

Section 498 (3), Taxes Consolidation Act, 1997

Origin: Direct Taxes International and Administration

File ref:1034/92




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