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.…