Reduced rate
12/04/1995
Query
Whether or not 75% of market value of company derives from qualifying trades where the 75% test has failed due to retained cash surplus.
Decision
Where the cash surplus derives from trading activities within the meaning of S.592 TCA 1997 and the profits are used for the purposes of the trade, the reduced rate will be allowed.
Capital Gains Tax
Section 592, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:G.162(A)(I)
09/02/1996
Query
Can companies carrying on complementary businesses be regarded as a group when applying the 75% test re qualifying trades?
Decision
Where individuals carry on business through a number of non group companies which carry on complementary businesses so as to form a composite unit of business, they may be regarded as coming within S.592(2)(b)(ii).
Capital Gains Tax
Section 592, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:G.162(A)