Revenue eBrief No. 084/26
22 April 2026
Company reconstruction or amalgamation: transfer of assets (section 615)
Tax and Duty Manual Part 20-01-02 provides guidance on the operation of relief from CGT on a company reconstruction or amalgamation, as provided for in section 615 of the Taxes Consolidation Act 1997.
The manual has been updated as follows:
- To reflect that the relief continues to apply to chargeable assets of companies resident in the United Kingdom following the enactment of the Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Act 2020 which was commenced by a Commencement Order made by the Minister for Finance with effect from 31 December 2020 (SI. No. 723 of 2020 refers).
- To streamline the contents of the manual to reflect the application of the current provision.