It begins with Section 28 and Section 60 of the Irish tax code. In his Budget speech in October 2019, the Minister for Finance Paschal Donohoe proposed immediate changes to both sections of the legislation, a move specifically designed to cut out loopholes that reduced tax on certain property transactions. Now, almost two years later, the import of those legislative changes, inserted into the budget speech just days before the speech, will be at the centre of a major High Court action between Henderson Park, the British private equity real estate giant, and various entities connected with the Irish state.…

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