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 portfolio to an unconnected purchaser. The purchaser was a company incorporated and tax resident in Ireland. At the time, the purchaser proposed to withhold 15% of the consideration payable unless that non-resident provided a tax clearance certificate. The non-resident contested the view...