The case of Cintra Infraestructureas Internacional SLU v The Revenue Commissioners [2023] IEHC 72 arose as a result of a disputed liability of a non-resident company to pay Irish capital gains tax (CGT) on profits accruing on the disposal of shares in Eurolink Motorway Operations Limited (“Eurolink”), an Irish-tax-resident company. That liability turned on whether the shares in Eurolink derived “their value or the greater part of their value directly or indirectly” from land in the State (s29(1A)(b) of the Taxes Consolidation Act 1997 (TCA 1997)), with the court noting that the case was essentially a question of interpretation.
To continue reading...
Members, students and subscribers of the Irish Tax Institute can login using your username and password.
For information on subscribing please contact info@taxinstitute.ie