Sections 579 and 579A TCA 1997 provide complex rules on the tax treatment of gains made by non-resident trusts. Finance Bill 2016 now provides that Irish beneficiaries of non- resident trusts will not be subject to the anti-avoidance CGT triggered under these provisions where it is shown to the satisfaction of the Revenue Commissioners that the trusts were established for bona fide commercial reasons and do not form part of an arrangement of which the main purpose or one of the main purposes is the avoidance CGT.