In Cintra Infraestructureas Internacional SLU v The Revenue Commissioners  IEHC 72 the High Court (Butler J) considered an appeal taken by Revenue against a determination of the Tax Appeals Commission (TAC). A Spanish company (Cintra) sold a majority stake in an Irish company (Eurolink). Eurolink had contracted with the National Roads Authority (NRA) to design, construct, operate, maintain and finance a motorway in Ireland. Ownership of the motorway and the land on which it was built remained vested in the NRA (which later became Transport Infrastructure Ireland (TII)). However, Eurolink was granted rights of access to the motorway “for the purposes of carrying out the project” (in effect, a licence) and also had the contract to collect the tolls on the motorway on behalf of the NRA/TII for a period of 30 years.