Brian Hayes (Dublin South West, Fine Gael) | Oireachtas source

This section exempts certain policies of assurance from CAT where neither the disponer nor the beneficiary of the policy is domiciled or ordinarily resident in the State. I understand this involves foreign life policies.

The intention of the legislation is to provide that life assurance policies are not subject to Irish CAT in the situation where neither the disponer nor the beneficiary of the policy is domiciled or ordinarily resident in Ireland, since they are normally subject to applicable taxes in the jurisdiction in which they are domiciled. Basically, it ensures they are not taxed twice on a policy. This is similar to a double taxation agreement for people with these policies.