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Commentary

IR2.6.3 Capital gains tax (CGT)


Republic of Ireland

Participation exemption on the sale of a subsidiary

TCA 1997, s 626B provides that a gain arising from the disposal of shares held by an Irish company is exempt from Irish CGT where:

  1. Ìý

    •ÌýÌýÌýÌý the Irish holding company has held at least 5% of the shares in the subsidiary for a continuous period of 12 months in the previous 24 months,; and

  2. Ìý

    •ÌýÌýÌýÌý the subsidiary company is tax resident in the EU or in a country with which a Double Tax Treaty is in force with Ireland at the time of disposal, and

  3. Ìý

    •ÌýÌýÌýÌý the subsidiary itself carries on a trade or is part of a trading group

  4. Ìý

    •ÌýÌýÌýÌý the shares in the subsidiary company do not derive their value from

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