MERGERS, DIVISIONS, TRANSFERS OF ASSETS AND EXCHANGES OF SHARES REGULATIONS

MERGERS, DIVISIONS, TRANSFERS OF ASSETS

AND EXCHANGES OF SHARES

SUBSIDIARY LEGISLATION 123.72

MERGERS, DIVISIONS, TRANSFERS OF ASSETS

AND EXCHANGES OF SHARES REGULATIONS

1st May, 2004

LEGAL NOTICE 238 of 2003, as amended by Legal Notice 59 of 2006.

The title of these regulations is the Mergers, Divisions,

Transfers of Assets and Exchanges of Shares Regulations.

* The Directive of 23 July, 1990 adopted by the Council of

the European Communities on a common system of taxation

applicable to mergers, divisions, transfers of assets and exchanges

of shares concerning companies of different Member States (90/

434/EEC) as amended by Council Directive 2005/19/EC of 17

February, 2005 amending Directive 90/434/EEC 1990 on the

common system of taxation applicable to mergers, divisions,

transfers of assets and exchanges of shares concerning companies

of different Member States shall have effect in relation to the

Income Tax Acts..

*L.N. 59 of 2006

The provisions of this regulation shall come into force on the 1 st January, 2007

Provided that in the case of those provisions of Council Directive 2005/19/EC of

17 February, 2005 amending Directive 90/434/EEC 1990 on the common system of

taxation applicable to mergers, divisions, transfers of assets and exchanges of shares

concerning companies of different Member States, which deal with -

(a) the transfer of the registered office of a European Company (SE) or

of a European Cooperative Society (SCE), and

(b) the entry (a) in the Annex thereto,

these provisions shall be deemed to have come into force on the 1 st January, 2006.