Zara founder snaps up last Dublin docklands project linked to Nama
founder Amancio Ortega's investment firm
Pontegadea
has bought a 6,344sq m (68,286sq ft) office building in Dublin's south docklands for almost €70 million from
US property group Kennedy Wilson
and the
National Asset Management Agency
(Nama), according to sources.
The deal to buy Ten Hannover Quay, a grade A office development let out to US financial technology group Fiserv, closed last week, the sources said. It marks Nama's final exit from the capital's docklands, where it had been involved in the large regeneration programme for more than a decade.
A spokesman for Nama, which owned 40 per cent of the building, declined to comment, while representatives for Kennedy Wilson and Pontegadea did not respond to requests for comment.
Nama, which was set up in 2009 to acquire about €72 billion of risky and distressed commercial property loans from Irish lenders, saw its remit widened about 13 years ago to deliver thousands of homes and develop swathes of land in the docklands that had fallen under its control as underlying loans ran into trouble.
READ MORE
This included sites previously controlled by Treasury Holdings, developer Harry Crosbie and the now-defunct Dublin docklands Development Authority.
Nama would work with partners such as Kennedy Wilson and US investment firm Oaktree, two of the most active buyers of Irish property assets in the wake of the property crash, Singapore-headquartered Oxley Holdings and Irish building contractor Bennett Construction to develop the land.
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Nama and its partners have delivered 3.8 million sq ft of commercial space, 2,000 homes, retail, cultural and green space across 15 sites on either side of the river Liffey over the past decade.
The sale of Ten Hanover Quay comes just three years after Fiserv signed up as tenants for the entire building, a modern glass-fronted office block integrated into an 1880s docklands warehouse overlooking Grand Canal Dock.
Fiserv is paying €57.50 per sq ft, almost €3.93 million in total, a year, with a rent review scheduled for 2027, according to an information memorandum distributed by estate agents CBRE and Savills, who handled the sale of the building, which has a freehold title.
Nama, which paid a deeply discounted price of €32 billion to acquire loans from Irish lenders during the financial crisis, had reduced the carrying value of its loan book to €370 million and its investment properties portfolio to €373 million by the end of last September, according to its latest quarterly report. This follows large portfolio sales and Nama working with certain debtors to develop and offload projects over the course of its lifespan.
The remains of the agency, together with what remains of Irish Bank Resolution Corporation, which is home to the remnants of Anglo Irish Bank and Irish Nationwide Building Society, are on track to move to a new resolution unit in the National Treasury Management Agency later this year.
Pontegadea, through which Mr Ortega holds most of his 59.2 per cent interest in Indetex, parent of Zara, Massimo Dutti, Pull & Bear and several other retailers, made its first foray into Ireland's commercial property market in March 2022, paying just over €100 million for 120 apartments at Opus at Six Hanover Quay in Dublin's south docklands.
It paid about €225 million for a big logistics investment at Dublin's Baldonnell Business Park, including a centre used by Amazon, about 18 months later.
Between those dates, Pontegadea entered and, subsequently, withdrew from talks to buy part of Meta's new Ballsbridge campus in Dublin for about €525 million.
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Should I be paying tax in UK on a pension if I live in Ireland?
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People who are neither tax resident nor domiciled in Ireland are the same as tax residents except they do not have to worry about tax on foreign income brought into the State. So, you are liable to tax in Ireland on all your earnings – and that means your gross UK pension, not the net amount after UK tax. That sounds like it might create an issue for you in relation to your Revenue filings for the past three years but there is a qualification to Irish liability to tax – it is subject to any relief due under the terms of a double taxation agreement. And we have one of them with the UK. Generally, under such agreements, there is a provision that your country of residence will allow a credit against your tax liability here in relation to any tax deducted in the other country. However, under the double taxation agreement between Ireland and the UK, there is also a specific measure relating to pensions. It states, among other things, that 'pensions and other similar remuneration paid in consideration of past employment to a resident of a contracting state and any annuity paid to such a resident shall be taxable only in that state. Resident of a contracting state means one of the two parties to an agreement. And those 'other things', well that relates to Government work (local or national) for which pensions are taxed in the state where that work was done. But even then, if you are an Irish citizen and not also a UK citizen, UK pensions for Government-related work would also be taxed here, not in the UK. So, no, you should not be liable to pay income tax in the UK on this UK occupational pension. And this is where I get annoyed because this is not a new agreement; it has been in force since 1976. So there is absolutely no reason why the UK revenue and the people paying your UK occupational pension should not be aware of it. Aptia sells itself as 'a specialist company that focuses on administration for pensions and benefits, with a global presence and a team of experienced and passionate professionals'. Is it possible you could be UK tax resident? It is but they know they are communicating with an Irish bank and an Irish address. And if there was a proper handover from the previous pension manager, they should be aware that certain pensions were being paid gross up to that point. So, at the very least, they should have known that there were queries to be made before arbitrarily taxing you in the UK – and possibly advice for you as a member of a scheme they managed if you were required to act in any way to ensure that happened. I'd love to say this is a one-off but I had a similar situation previously with a large, publicly-listed UK firm. And despite making the case to them that the pension involved was not liable to tax in the UK, they insisted on continuing to do so. There are only two possible reasons for this: either these pensions specialists do not train their people properly or they simply do not care. Neither is very encouraging. Your situation is even more daft. Not only are you not now a UK resident (for tax purposes), you have never been resident in the UK – to the extent that you were unaware you even had a national insurance number. Recouping your money So what now? The good news is that you should be able to reclaim the tax paid over the past three years in the UK and ensure that Aptia henceforth pay your UK occupational pension to you gross. It will then be taxed here in Ireland. The bad news is twofold. One, you obviously need to amend your Irish tax returns for the relevant years as you are liable here for tax on the gross UK pension, not the net amount. Second, as I can attest from going through the process, it can takes well over a year (literally) to get this sorted with His Majesty's Revenue and Customs (HMRC). However, it appears the system has been streamlined somewhat since I fought my way through it a decade ago. The first thing you need to do is download Form IRL-Individual, which can be found here . You will see an accompanying file with notes on how to complete the form. Take the time to make sure everything is correct or it will only be sent back to you, delaying things. Importantly, although this is a HMRC form, you must return it to the Irish Revenue in the first instance – at whatever office deals with your income tax affairs. They need to stamp and sign the form to confirm you are Irish tax resident and they then send the form direct to their UK counterparts. Once the UK is happy with the details, they will refund any tax deducted in error in past tax years – i.e. up to April 2025 – to your Irish bank account. They will also confirm your status with Aptia, which should then arrange for repayment of any tax deducted from your UK pension in the current UK tax year and pay your UK pension into your Irish bank account gross going forward. Please send your queries to Dominic Coyle, Q&A, The Irish Times, 24-28 Tara Street, Dublin 2, or by email to , with a contact phone number. This column is a reader service and is not intended to replace professional advice
