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Irish Tax Appeals Commission Finds Disposal of Portfolio of Irish Mortgage Loans Constitutes Disposal of an Interest in Land Subject to Capital Gains Tax

|Approved Changes|Ireland
Ireland

Ireland's Tax Appeals Commission (TAC) has published Determination 72TACD2023 regarding Capital Gains Tax (CGT) on the disposal of a portfolio of Irish mortgage loans by a non-resident company. The mortgage loans comprising the Portfolio were loans advanced to individuals and one company and were secured over properties in Ireland.

In 2016, the non-resident company agreed to sell the portfoli…

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