1. Irish Financial Services Law
  2. Legislation (IE)
  3. Acts
  4. 1997
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  1. Taxes Consolidation Act, 1997 (No. 39)
  2. Income Tax and Corporation Tax: The Main Provisions (ss. 32-531)
  3. Part 6 Company Distributions, Tax Credits, Franked Investment Income and Advance Corporation Tax (ss. 129-186)
  4. Chapter 6 Distributions - supplemental (ss. 152-155)
  5. 155. Restriction of certain reliefs in respect of distributions out of certain exempt or relieved profits.
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Version status: In force | Document consolidation status: Updated to reflect all known changes
Version date: 6 February 2003 - onwards
  Version 3 of 3    

155. Restriction of certain reliefs in respect of distributions out of certain exempt or relieved profits.

(1) In this section, "distribution" has the same meaning as in the Corporation Tax Acts.

(2)

(a) This section shall apply to shares in a company where any agreement, arrangement or understanding exists which could reasonably be considered to eliminate the risk that the person beneficially owning those shares -

(i) might, at or after a time specified in or implied by that agreement, arrangement or understanding, be unable to realise directly or indirectly in money or money's worth an amount so specified or implied, other than a distribution, in respect of those shares, or

(ii) might not receive an amount so specified or implied of distributions in respect of those shares.

(b) The reference in this subsection to the person beneficially owning shares shall be deemed to be a reference to both that person and any person connected with that person.

(c) For the purposes of this subsection, an amount specified or implied shall include an amount specified or implied in a foreign currency.

(3) W

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