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Additional protocol between Ireland and Portugal signed

01 January 2006

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Treaty Development

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Ireland-Portugal

Ireland and Portugal signed on 11 November 2005 in Lisbon an additional protocol to the existing tax treaty of 1 June 1003.. The new protocol may have tax implications for Irish residents relocating to Portugal since it provides that individuals who change their residence and subsequently dispose of shares held in Irish companies, may nevertheless be subject to Irish capital gains tax. This is the result of several high profile cases of Irish resident individuals moving their tax residence to Portugal. The existing tax treaty provides that the residence state retains exclusive taxing rights on gains derived from the disposal...