XYZ Ltd, an Irish company, buys land in Germany from Hans.
Instead of paying money to Hans for the land, XYZ Ltd issues shares to Hans.
Hans executes the instrument that transfers the land to XYZ Ltd in Germany.
XYZ Ltd must pay Stamp Duty because something was done in Ireland. XYZ Ltd issued the shares in Ireland.
In addition, Stamp Duty is chargeable because the instrument relates to property in Ireland (the shares in XYZ Ltd).