Readers' forum: Property portfolio

02 April 2019

Issue: 4690 / Categories: Forum & Feedback

Double tax treaty on property profits in Eire.

My client is an Irish citizen who has been resident in the UK for the past 35 years. He owns a very large portfolio of residential investment properties in the UK some of which are held by him personally. However the majority of the properties are owned by a UK resident company of which he is the controlling shareholder.

My client is now proposing to acquire jointly with another UK citizen who is currently resident in the Irish Republic a portfolio of ten residential property investments located in the Irish republic for about €500 000.

To facilitate ownership of this property portfolio in Ireland they are going to set up a new UK resident company that will own the Irish properties. The shares in the new UK resident company will be owned 50% by my client and his co-investor.

I have looked at Article 21 of the UK...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Subscribe Now...

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.

Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.