Under the EU Anti-Tax Avoidance Directive (ATAD), a deemed disposal will arise where an Irish company:
- Relocates assets from Ireland to abroad (i.e., outside the EU).
- Relocates a business carried on in Ireland to abroad.
- Relocates itself abroad, i.e., becomes non-Irish resident.
The deemed disposal will give rise to 12.5% exit tax.
Revenue reserve the right to impose 33% CGT if they are of the view that a disposal forms part of a tax avoidance transaction.
Exit tax can be paid in 6 equal annual instalments.