(1) Part 19 of the Principal Act is hereby amended in Chapter 3 by the insertion after section 579 of the following sections:
"579A. Attribution of gains to beneficiaries.
(a) For the purposes of this section and the following sections of this Chapter, 'capital payments' means any payment which is not chargeable to income tax on the recipient or, in the case of a recipient who is neither resident nor ordinarily resident in the State, any payment received otherwise than as income, but does not include a payment under a transaction entered into at arm's length.
(b) In paragraph (a) references to a payment include references to the transfer of an asset and the conferring of any benefit, and to any occasion on which settled property becomes property to which section 567(2) applies.
(c) The amount of a capital payment made by way of loan, and of any other capital payment which is not an outright payment of money, shall be taken to be equal to the value of the benefit conferred by it.
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