Reduced rate/earn outs

09/02/1996

Query

Does an entitlement to additional consideration under an earn out qualify for relief under S.592?

Decision

As the amounts received in an earn out are in respect of a right separate to shares which were disposed of, they will not qualify for the relief. However, in practice, cash earn-outs may be treated as qualifying for the relief.

Capital Gains Tax

Section 592, Taxes Consolidation Act, 1997

Origin: RLS Division

File ref:G.162(L)




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