Revenue eBrief No.110/23
03 May 2023
Stamp Duty Tax and Duty Manual - "Section 31D: Cancellation schemes of arrangement" - Updated
Stamp Duty Manual - Part 5: Section 31D - Cancellation schemes of arrangement - contains guidance on the application of section 31D of the Stamp Duties Consolidation Act 1999 (SDCA).
The manual has been updated to clarify Revenue's position following a Tax Appeals Commission determination in respect of section 31D SDCA, where it found that section 31D was contrary to the Capital Duties Directive. It should be noted that Revenue disagrees with this determination and has not changed its position in relation to section 31D SDCA in light of the determination.