Revenue eBrief No. 027/20

04 February 2020

Anti-Tax Avoidance Directive (ATAD) - Exit Tax

Tax and Duty Manual Part 20-02-01 has been updated at paragraph 1.1 to reflect the amendments made by Finance Act 2019 (section 38) to the Exit Tax legislation introduced in Finance Act 2018. The amendments ensure that

  • the deemed disposal and reacquisition of assets on the change of residence is deemed to arise immediately before the change of residence of the company concerned, and
  • the charge on the transfer of assets, or the business, of a permanent establishment in the State arises regardless of the residence of the company concerned.