Taxes Consolidation Act 1997 section 620

Replacement of business assets by members of group

Section 620 modifies rollover relief under section 597 so that it can operate across a group of companies, by treating all trades carried on by group members as a single trade.

• Where a group member disposes of a trading asset and another group member acquires a replacement trading asset, rollover relief under section 597 may apply as if both companies carried on the same trade.
• The single trade treatment does not apply where the old assets are disposed of to, or the new assets are acquired from, another member of the same group.
• The section applies to trades carried on by Irish resident companies and to trades carried on in the State through a branch or agency by non-resident companies.
• For non-resident companies, the assets concerned must be chargeable assets in relation to the company at the relevant time.