Revenue eBrief No. 159/22

08 August 2022

Section 701, transfer of shares held by certain societies to society members

Tax and Duty Manual Part 25-01-04 has been updated to remove previous guidance regarding ‘patronage shares’. This removal reflects Revenue's acceptance that shares issued by a co-operative at a value less than market value to members arising from the trading relationship between the member and the co-operative (or a nominated purchaser), otherwise known as patronage shares, does not give rise to a trading receipt within the charge to income tax.