Revenue eBrief No. 122/20

24 June 2020

Stamp duty: associated companies relief

The stamp duty tax and duty manual on associated companies relief (section 79 Stamp Duties Consolidation Act 1999) has been amended to clarify a number of matters in relation to certain conditions for the relief and certain Revenue practices. These matters relate to:

  • the retention of property within a corporate group post transfer-
    • the type of property that, by its nature, ceases to exist
    • the extinguishing of shares in a transferred company following its liquidation
  • the application of practices to both transferee and transferor
  • the holding of the issued share capital of foreign bodies corporate
  • change in ownership of shares in listed companies post transfer
  • timing of transfers of property and series of mergers
  • liquidations and mergers under foreign law.