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Clients of mine are planning their return to Ireland. Both Irish domiciled. The wife will become Irish tax resident on 1 January 2021. The husband, a pilot, will remain Irish non-resident for the foreseeable future. They own a South African holiday home. The intention is to transfer the asset into the husband’s name in 2020 and before the wife becomes Irish tax resident. My reading of s1028(6A) is that we are not caught as neither spouse is tax resident in 2020. Is this correct and is there other anti-avoidance we might be falling foul of?

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Asked on 23 May 2020 12:55 pm