Steph Wickham

Okay.

So that's one point.

For the latter category, you're really looking at, you know, a planning exercise and...

It's definitely warranted.

So for each of the different kind of income and assets you mentioned, there'll be considerations, but let's pick some of the headline ones.

There's an anti-avoidance provision in Irish legislation in Section 29A of the Tax Act that basically is designed to disincentivise people from going outside of Ireland for limited periods of time, five years, namely...

selling an asset while outside the reach of the Irish taxman and then returning to Ireland subsequent.

So you would need to have that conversation with the client and make them aware of that.

Some of our double tax agreements are actually tweaked to take that provision into account.

And, you know, some of the tax friendly jurisdictions that we have treaties with tend to be in the Middle East.

And what we've seen in some recent tax appeal cases is that treaty protection is not as extensive as we would like it to be.

What do I mean by that?

Well, when you look at the way that the double tax agreement with the UAE, for example, is written, it is quite clear that to be considered a resident of the UAE, you are somebody who is liable to tax there.

Now, I don't believe revenue have been as successful as they'd like to be in this claim, but it does go to show that the line of thinking is you can't rely on a treaty if you're not subject to tax in the jurisdiction.

And that is one of the definitions required to offer treaty protection.

What does this mean?

It means that if you've got somebody going to the Middle East and they have acquired...

portfolio of assets and they're planning to liquidate it they really need to take tax advice to escape both the ordinary residency tax charge that I mentioned and potentially to be cognizant of how section 29a might apply in practice to them so this is an area where sometimes bar stool talk can be very dangerous because John will tell Michael that

that he got advice about this and then there's a conception that this is what applies.

It can be very nuanced and specific on the circumstances that we're looking at.