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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...

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