Revenue eBrief No. 090/26

18 May 2026

Requests for Clearance – Disposal of Land and Buildings by non-resident vendors

Tax and Duty Manual Part 45-01-05 - Requests for Clearance – Disposal of Land and Buildings (e.g. Specified assets) by non-resident vendors - outlines the clearance process that has been agreed between Revenue and practitioners for disposals of land and buildings by non-resident vendors. The document has been updated as follows:

• Section 2 has been updated to provide clarification that a clearance request must be submitted in circumstances where no chargeable gain arises, and the property had been rented during the period of ownership. Where there is no requirement to submit a clearance request to Revenue, the vendor should provide the solicitor with written confirmation that the property has not been rented during the period of ownership. This requirement has been added to Section 4(g). Point 1 in the summary table in Section 5 has also been updated to reflect this amendment.
• Section 2.2.1 has been updated to reflect section 1042(1) TCA 1997, which provides that a non-resident individual disposing of specified assets is liable to pay CGT by the later of three months after the date of disposal, or two months after the date the assessment issues. S959AE(1) outlines the situations when the Inspector can make an assessment prior to the return date which includes when tax is due on the disposal of specified assets by a non-resident vendor.
• The words “(e.g. Specified assets)” have been removed from the title to reflect the fact that the clearance process applies to disposals of land and buildings by non-resident vendors.