Revenue published updated Capital Gains Tax (CGT) guidance on 12 October 2026, incorporating changes from Finance Act 2026 and recent Appeal Commission determinations. The revised manual provides detailed clarification on the Entrepreneur Relief lifetime limit of €1 million, including the definition of ‘qualifying business assets’ and the requirement for a minimum 3-year holding period. New sections address the valuation of unquoted shares for CGT purposes following the ‘Dwyer’ High Court decision, and the CGT implications of share-for-share reorganisations under Section 584 TCA 1997. The guidance also updates the indexation allowance freeze (effective 2003) and the interaction with the new 30% R&D tax credit.
Key Takeaways
- Entrepreneur Relief Tightened: Strict 3-year continuous ownership and ‘working director’ tests apply; guidance includes flowchart for eligibility determination.
- Unquoted Share Valuation: ‘Dwyer’ principles now codified: valuation must reflect arm’s length price considering minority discounts and lack of marketability.
- Reorganisation Relief: Section 584 relief available only where genuine commercial reasons exist; anti-avoidance provisions target tax-driven restructuring.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement