Revenue’s guidance on the Exit Tax rules that were introduced by Finance Act 2018 and contained in section 627 Taxes Consolidation Act 1997 is updated to include the amendments made by Finance Act 2019.

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.