Mandatory Disclosure of Certain Transactions Regulations, 2011 (S.I. Number 7 of 2011)
14 Income into capital schemes
(1) This Regulation applies to a transaction where, as a consequence of the transaction, a person who would otherwise incur, or be expected to incur, a liability to income tax in any tax year, will—
(a) incur, or be expected to incur, a lesser or nil liability to income tax chargeable in that year, and
(b) acquire an asset, the disposal of which would, in principle, be a chargeable gain under the Principal Act.
(2) For the purposes of paragraph (1) a chargeable gain includes a gain on the disposal of assets that are exempt from capital gains tax or relieved from capital gains tax under any of the provisions of the Principal Act.
(3) Notwithstanding paragraph (1) and without prejudice to Regulations 8 and 9, a transaction shall not be a transaction of a kind described in this Regulation where it is a transaction of a kind specified in the Schedule.