Irish Revenue has issued eBrief No. 008/23 concerning an update to the guidance, Tax and Duty Manual Section-31D- Cancellation schemes of arrangement. The guidance concerns an anti-avoidance rule (Section 31D) introduced as part of the Finance Act 2019 to impose a stamp duty charge (1% rate on shares) on the court-approved acquisition of companies involving the cancellation of existing shares and the issue of new shares as consideration (known as "cancellation schemes of arrangement"). Prior to the rule, such cancelation schemes of arrangement could be used to avoid stamp duty since they did not involve an actual transfer of shares...