87. Amendment of general anti-avoidance rule
(1) Chapter 2 of Part 33 of the Principal Act is amended -
(a) in section 811 by inserting the following subsection after subsection (13) of section 811:
"(14) This section shall only apply to a transaction which was commenced on or before 23 October 2014.",
(b) in section 811A by -
(i) inserting the following subsection after subsection (2):
(a) In this subsection 'qualifying avoidance disclosure' means a disclosure that the Revenue Commissioners are satisfied is a disclosure of complete information in relation to, and full particulars of, a transaction that is a tax avoidance transaction or that, had the Revenue Commissioners formed the opinion that the transaction was a tax avoidance transaction, would occasion a liability to tax pursuant to section 811, made in writing to the Revenue Commissioners and signed by or on behalf of that person and which is accompanied by -
(i) a declaration, to the best of that person's knowledge, information and belief, made in writing, that all matters contained in the disclosure are correct and complete, and