Non-resident company loses €1.09m tax appeal

📆 15/05/2023 5:09 p. m.
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Tax Appeals Commission rules business was not entitled to capital gains tax repayment via IrishTimesBiz

In 2016, the firm agreed to sell the portfolio to an unconnected purchaser which is a company incorporated and tax resident here.

Ultimately, the firm agreed to pay €1.092 million to Revenue on a ‘without prejudice’ basis in order that the sale of the portfolio could be completed. An expert witness for the firm told the TAC that the company purchased distressed loans with a view to disposing of them but also that part of the intention of acquiring them was to generate cash flow during the hold period from payments being made by the borrowers.

He stated that he thought it very likely that receivers were appointed in relation to some of the loans from the portfolio.

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Company loses €1.09m tax appealTax Appeal Commission ruled business was not entitled to capital gains tax repayment
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