William Fry’s Tax Litigation & Disputes team was involved in a landmark tax case that considered if a Spanish company’s 2016 sale of unquoted shares in an Irish PPP company was within the charge to Irish capital gains tax.
In the recent High Court case of Cintra Infraestructuras Internacional SLU V The Revenue Commissioners William Fry acted for Cintra in defending Revenue’s appeal of Tax Appeals Commission (TAC) determination 75TACD2021. In 2021 the TAC determined that the 2016 sale by Cintra of shares in Eurolink Motorway Operations Limited (an Irish PPP company) was not within the charge to Irish capital gains tax on the basis that the Eurolink shares disposed of did not derive their value directly or indirectly from “land in the State” (i.e. Irish land and buildings).
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