The saga begins in 2007 when the taxpayer, an Irish resident, borrowed €4.3 million from a French bank with an Irish branch. The borrowings were used to buy shares in a French company (“FrenchCo”). As security, the borrower pledged up 155,000 company shares. In 2008, a further €7.7 million was borrowed and another 366,512 shares were secured by the bank. The 2007 and 2008 loan agreements stated that, in the event of a fall in value of the shares pledged as security, the borrower would have to stump up more collateral against the loan. If the borrower couldn’t shore up, the…

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