Links from Section 586 | ||
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Act | Linked to | Context |
Taxes Consolidation Act, 1997 |
(1) Subject to section 587, where a company issues shares or debentures to a person in exchange for shares in or debentures of another company, section 584 shall apply with any necessary modifications as if the 2 companies were the same company and the exchange were a reorganisation of its share capital. |
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Taxes Consolidation Act, 1997 |
(1) Subject to section 587, where a company issues shares or debentures to a person in exchange for shares in or debentures of another company, section 584 shall apply with any necessary modifications as if the 2 companies were the same company and the exchange were a reorganisation of its share capital. |
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Taxes Consolidation Act, 1997 |
(3)(a) In this subsection, “shares” includes stock, debentures and any interests to which section 587(3) applies and also includes any option in relation to such shares. |
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Taxes Consolidation Act, 1997 |
(ii) the company issuing the debentures, loan stock or other similar securities and the person to whom they are issued are members of the same group (within the meaning of section 616) throughout the period commencing one year before and ending one year after the day the debentures, loan stock or other similar securities are issued, or |
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Taxes Consolidation Act, 1997 |
(d) This section shall not apply where the company issuing the shares or debentures is an investment undertaking within the meaning of section 739B. |
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Links to Section 586 (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(d) a company which issued the shares to the trustees of an employee share ownership trust to which section 519 applies, in an exchange to which section 586 applies, which shares were transferred to the trustees of an approved scheme by the trustees of the employee share ownership trust. |
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Taxes Consolidation Act, 1997 |
(b) if they are securities issued to the trustees in exchange in circumstances mentioned in section 586. |
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Taxes Consolidation Act, 1997 |
(b) if securities are issued to the trustees in exchange in circumstances mentioned in section 586, they shall be treated as having acquired them when they became entitled to the securities for which they are exchanged. |
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Taxes Consolidation Act, 1997 |
(1) In this paragraph “original shares” and “new holding” shall be construed in accordance with sections 584, 586 and 587. |
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Taxes Consolidation Act, 1997 |
in circumstances such that, under section 584 as that section applies by virtue of section 586 or 587, the original shares and the new holding are treated as the same asset. |
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Taxes Consolidation Act, 1997 |
(10) Where for the purposes of capital gains tax the time when a person acquired shares would be determined under section 584, 585, 586, 587 or 600, then, unless the person is to be treated under section 584(4) as giving or becoming liable to give any consideration, other than the old holding, for the acquisition of those shares, it shall be determined in the same way for the purposes of this section. |
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Taxes Consolidation Act, 1997 |
(II) section 584 is applied or, but for section 626B, would be applied to the exchange by section 586, and |
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Taxes Consolidation Act, 1997 |
(i) securities issued to the trustees of the employee share ownership trust referred to in paragraph (a) in an exchange to which section 586 applies, |
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Taxes Consolidation Act, 1997 |
(b) in a case where section 584, 586 or 587 applies, the shares received in exchange for the shares so acquired, |
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Taxes Consolidation Act, 1997 |
(b) Where a quoted option to subscribe for shares in a company is dealt in within 3 months after the taking effect, with respect to the company granting the option, of any reorganisation, reduction, conversion or amalgamation to which section 584, 585, 586 or 587 applies (or within such longer period as the Revenue Commissioners may by notice in writing allow), the option shall for the purposes of section 584, 585, 586 or 587 be regarded as the shares which could be acquired by exercising the option, and section 548(3) shall apply for determining its market value. |
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Taxes Consolidation Act, 1997 |
(b) Where a quoted option to subscribe for shares in a company is dealt in within 3 months after the taking effect, with respect to the company granting the option, of any reorganisation, reduction, conversion or amalgamation to which section 584, 585, 586 or 587 applies (or within such longer period as the Revenue Commissioners may by notice in writing allow), the option shall for the purposes of section 584, 585, 586 or 587 be regarded as the shares which could be acquired by exercising the option, and section 548(3) shall apply for determining its market value. |
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Taxes Consolidation Act, 1997 |
(2) Subject to subsection (1) and sections 585 and 586, the satisfaction of a debt or part of a debt (including a debt on a security within the meaning of section 585) shall be treated for the purposes of the Capital Gains Tax Acts as a disposal of the debt or of that part by the creditor made at the time when the debt or that part is satisfied. |
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Taxes Consolidation Act, 1997 |
(3) Where property is acquired by a creditor in satisfaction of the creditor’s debt or part of that debt, then, subject to sections 585 and 586, the property shall not be treated for the purposes of the Capital Gains Tax Acts as disposed of by the debtor or acquired by the creditor for a consideration greater than its market value at the time of the creditor’s acquisition of it; but, if under subsection (1) (and in a case not within either section 585 or 586) no chargeable gain is to accrue on a disposal of the debt by the original creditor and a chargeable gain accrues to that creditor on a disposal by that creditor of the property, the amount of the chargeable gain shall (where necessary) be reduced so as not to exceed the chargeable gain which would have accrued if that creditor had acquired the property for a consideration equal to the amount of the debt or that part of the debt. |
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Taxes Consolidation Act, 1997 |
(3) Where property is acquired by a creditor in satisfaction of the creditor’s debt or part of that debt, then, subject to sections 585 and 586, the property shall not be treated for the purposes of the Capital Gains Tax Acts as disposed of by the debtor or acquired by the creditor for a consideration greater than its market value at the time of the creditor’s acquisition of it; but, if under subsection (1) (and in a case not within either section 585 or 586) no chargeable gain is to accrue on a disposal of the debt by the original creditor and a chargeable gain accrues to that creditor on a disposal by that creditor of the property, the amount of the chargeable gain shall (where necessary) be reduced so as not to exceed the chargeable gain which would have accrued if that creditor had acquired the property for a consideration equal to the amount of the debt or that part of the debt. |
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Taxes Consolidation Act, 1997 |
(b) in exchange for shares in or debentures of another company where the requirements of section 586(2) are satisfied in relation to the exchange, |
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Taxes Consolidation Act, 1997 |
(b) this section has application by virtue of section 586. |
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Taxes Consolidation Act, 1997 |
(2) Where under any arrangement between a company and the persons holding shares in or debentures of the company or any class of such shares or debentures, being an arrangement entered into for the purposes of or in connection with a scheme of reconstruction or amalgamation, another company issues shares or debentures to those persons in respect of and in proportion to (or as nearly as may be in proportion to) their holdings of the first-mentioned shares or debentures, but the first-mentioned shares or debentures are either retained by those persons or cancelled, then, those persons shall be treated as exchanging the first-mentioned shares or debentures for those held by them in consequence of the arrangement (any shares or debentures retained being for this purpose regarded as if they had been cancelled and replaced by a new issue), and accordingly section 586(1) shall apply to such exchange of shares or debentures. |
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Taxes Consolidation Act, 1997 |
(3) Subsection (2) shall apply in relation to a company which has no share capital as if references to shares in or debentures of a company included references to any interests in the company possessed by members of the company, and sections 584 and 586 shall apply accordingly. |
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Taxes Consolidation Act, 1997 |
(4)(a) In this subsection, “shares” has the same meaning as in section 586(3). |
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Taxes Consolidation Act, 1997 |
(I) a company that was treated as being the same company, for the purposes of section 586, as a relevant company, or |
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Taxes Consolidation Act, 1997 |
(I) a company that was treated as being the same company, for the purposes of section 586, as a relevant company, or |
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Taxes Consolidation Act, 1997 |
(I) a company that was treated as being the same company as the relevant company for the purposes of section 586, |
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Taxes Consolidation Act, 1997 |
(a) section 586 or 587 applies to shares in a company so as to equate them with shares in or debentures of another company, and |
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Taxes Consolidation Act, 1997 |
(3) The references in subsection (2) to section 584 do not include references to that section as applied by section 585 or 586. |
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Taxes Consolidation Act, 1997 |
(5) Notwithstanding anything in section 586 or 587, in any case where— |
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Taxes Consolidation Act, 1997 |
then, section 586(1) shall not apply for the purposes of this Chapter. |
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Taxes Consolidation Act, 1997 |
(6) In any case where (apart from subsection (5)) section 586(1) would apply, the exchange concerned of shares, debentures or other interests in or of a non-qualifying fund shall for the purposes of this Chapter constitute a disposal of interests in the offshore fund for a consideration equal to their market value at the time of the exchange. |
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Taxes Consolidation Act, 1997 |
(6) The reference in subsection (5) to section 584(3) shall be deemed to include a reference to that section as applied by section 586 or 733 but not as applied by section 585. |
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Taxes Consolidation Act, 1997 |
(a) on which the interest acquired constituted the new holding for the purposes of section 584, including that section as applied by section 585 or 586, and |
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Taxes Consolidation Act, 1997 |
(3) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the disposal of an asset giving rise to a chargeable gain or an allowable loss under the Capital Gains Tax Acts and the Corporation Tax Acts shall for the purposes of this section constitute such a disposal. |
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Taxes Consolidation Act, 1997 |
(5)(a) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the disposal of an asset shall for the purposes of this section constitute such a disposal. |
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Taxes Consolidation Act, 1997 |
(b) An event which, apart from section 584(3) as applied by section 586 or 587, would constitute the acquisition of an asset shall for the purposes of this section constitute such an acquisition. |