Section 64 Finance Act 2012 introduces an attractive Capital Gains Tax (CGT) exemption for persons (individuals, companies, trusts etc.) in respect of property purchased between midnight on 6 December 2011 and the end of 2013.
If a property is acquired during this period and held for at least 7 years, the capital gain related to that 7 year holding period will be fully relieved from Irish CGT.
The exemption will work to time-apportion gains so that a property held for 10 years will be 7/10ths exempt from CGT, while a property held for 7 years will be entirely exempt (7/7ths).
Land and buildings situated in the EEA countries, includes all EU countries and in addition Norway, Iceland and Leichtenstein.
This is a very attractive relief, in particular with regard to Irish property and indeed UK property held by a non-UK resident (e.g. an Irish resident company). It could also be usefully used in respect of EEA countries with low rates of CGT or low rates of withholding tax for non-residents.