Preparing for Pay and File 2023: Tips and Tricks
Lauren Clabby provides guidance on completing the 2022 Form 11, including a review of relevant eBriefs published by Revenue and a comparison of the 2022 Form 11 with the 2021 version....
ePSWT: A Guide for the Tax Practitioner
Feargal Kinsella provides an overview of the electronic system for professional services withholding tax, introduced in 2021, and explains how interim refunds can be claimed....
Key Considerations for the Corporation Tax 2022 Cycle
Kelly Caffrey explains the key considerations to be taken into account for the 2022 corporation tax compliance cycle. ...
Interest Limitation Rule: CT1 Disclosures and Updated Revenue Guidance
Angela Fleming and Yvonne Diamond provide a practical guide for corporation tax filers that explains disclosure requirements on the CT1 regarding interest limitation rules....
Capital Taxes Compliance Considerations
Siobhán O’Moore and Adrian Farragher outline the main CAT and CGT compliance issues that should be considered by both individuals and companies....
The Domicile Levy: Relevance to Tax Returns 2022
Anne Hogan provides an analysis of Part 18C, s531AA to s531AK, TCA 1997, which deals with the domicile levy payable by certain individuals, highlighting the points to be considered for taxpayer compliance...
Tax-Compliant Capital Allowance Claims for Property Investors
Philip O’Connor outlines an incentive that can provide landlords with considerable tax relief yet is often not used – capital allowances for plant and machinery fixtures attached to investment property....
Irish Transfer Pricing Requirements Refresher
Anthony Crewe provides a high-level review of the recent changes to the Irish transfer pricing rules, highlighting their application to companies and branches operating in Ireland and the consequences of non-compliance....
Section 135(3A) TCA 1997: Common Traps and Pitfalls to be Aware of
Paul Morris and Michael O’Brien consider s135(3A) TCA 1997, which treats certain capital transactions as income distributions but, unlike similar provisions, contains no “bona fide commercial reasons” protection....
The Taxation of Certain Compensatory Payments to Employees
Aidan Fahy, Audrey Kean and Siún Clinch critically examine recent determinations of the Tax Appeals Commission dealing with the interaction between s123 TCA 1997 and other relieving sections, including ss192A and 613...
Residence, Domicile and Double Taxation Relief – Recent Case Law Issues
Jeananne McGovern and Sara-Jane O’Brien focus on potential taxation issues that can arise for individuals with income from outside the State and provide an analysis of some recent cases and determinations....
Editor’s Pages
Issue 2, 2023 Editor’s Pages Published June 28, 2023 in Issue 2, 2023 Julie Burke, Editor Table of Contents Back to top Preparing for Pay and File 2023: Tips and Tricks Lauren...
Group Rationalisation Post-Acquisition: Part 2
Úna Ryan and Caroline Kennedy discuss the anti-avoidance provisions that apply to group restructurings and reorganisations....
Policy and Representations Monitor
Issue 2, 2023 Policy and Representations Monitor Published June 28, 2023 in Issue 2, 2023 Lorraine Sheegar, Tax Manager, Tax Policy & Representations, Irish Tax Institute Table of Contents Back to top...
Recent Revenue eBriefs
Issue 2, 2023 Recent Revenue eBriefs Published June 28, 2023 in Issue 2, 2023 Lorraine Sheegar, Tax Manager, Tax Policy & Representations, Irish Tax Institute Back to top Revenue eBriefs Issued from...
Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations
Issue 2, 2023 Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations Published June 28, 2023 in Issue 2, 2023 Mark Ludlow, Senior Associate – Tax, RDJ LLP...
Direct Tax Cases: Decisions from the UK and European Courts
Issue 2, 2023 Direct Tax Cases: Decisions from the UK and European Courts Published June 28, 2023 in Issue 2, 2023 Stephen Ruane, Partner and Leader, Tax Solutions Centre, PwC Ireland Patrick...
International Tax Update
Issue 2, 2023 International Tax Update Published June 28, 2023 in Issue 2, 2023 Louise Kelly, Tax Partner, Deloitte Ireland LLP Claire McCarrick, Tax Senior Manager, Deloitte Ireland LLP Table of Contents...
VAT Cases & VAT News
Issue 2, 2023 VAT Cases & VAT News Published June 28, 2023 in Issue 2, 2023 Gabrielle Dillon, Director – VAT, PwC Ireland Table of Contents Back to top VAT Cases Intra-Community...
Accounting Developments of Interest
Issue 2, 2023 Accounting Developments of Interest Published June 28, 2023 in Issue 2, 2023 Aidan Clifford, Advisory Services Manager, ACCA Ireland Table of Contents Back to top Insolvency Practitioners and Anti-Money...
Revenue Commissioners’ Update
Issue 2, 2023 Revenue Commissioners’ Update Published June 28, 2023 in Issue 2, 2023 Table of Contents Back to top EU Cross-Border eCommerce Payments Reporting Overview On 18 February 2020, the European...
Legal Monitor
Issue 2, 2023 Legal Monitor Published June 28, 2023 in Issue 2, 2023 Philip McQueston, Of Counsel, A&L Goodbody Table of Contents Back to top Selected Acts Signed into Law from 1...
Tax Appeals Commission Determinations
Issue 2, 2023 Tax Appeals Commission Determinations Published June 28, 2023 in Issue 2, 2023 Catherine Dunne, Barrister-at-Law Table of Contents Back to top Published from 1 February to 30 April 2023...
Tax Technology Update – Summer 2023
Issue 2, 2023 Tax Technology Update – Summer 2023 Published June 28, 2023 in Issue 2, 2023 Andrew Egan, Director, Tax Transformation & Technology, KPMG Table of Contents Back to top Introduction...
UK and Northern Ireland Tax Update – Summer 2023
Issue 2, 2023 UK and Northern Ireland Tax Update – Summer 2023 Published June 28, 2023 in Issue 2, 2023 Marie Farrell, Tax Director, KPMG Ireland (Belfast Office) Table of Contents Back...
Key Dates Calendar
This regular feature includes key tax dates for individuals and companies in relation to filing and other obligations. Updates include those as published by the Office of the Revenue Commissioners. Readers may...
President’s Pages
Quarter 2 got off to a flying start with our return to the Galmont Hotel in Galway for the Institute’s first in-person Annual Conference in four years. There was a great buzz...
Chief Executive’s Pages
First, I want to thank you all for renewing your subscriptions and submitting your CPD declarations. We also wrote to you requesting you to participate in our research project on the career in...
News & Moves
News and moves in the tax community ...
Contributors’ Stories: Getting Involved with Your Institute
Louise Graham Tax Manager, PwC Ireland ...
President’s Pages
It has been a productive and eventful first quarter for the Institute, and the highlight was the Annual Dinner, which returned this year to its customary slot at the end of February....
Chief Executive’s Pages
By the end of 2022 I was already anticipating the many familiar and new faces that would join us in-person during 2023. I’m delighted that the first three months have not disappointed,...
News & Moves
News and moves in the tax community.........
Employment Tax Matters: Finance Act 2022
Pat O’Brien provides a summary and analysis of the key provisions in the Finance Act 2022 relating to employment tax matters....
Revenue’s Code of Practice for Compliance Interventions
Aidan Lucey and Mark Barrett explore the core components of the new Code and Compliance Intervention Framework, in force since 1 May 2022, and assess some of the early trends to emerge....
Temporary Business Energy Support Scheme: Overview of Rules and Key Points for SMEs
Emma Arlow provides an overview of the Temporary Business Energy Support Scheme, including definitions and key checklist items for companies, as well as a brief run-down of other relevant tax supports for...
Taxation Considerations on Transitioning to Emergency Accommodation
Stephen Gahan and Oonagh Carney provide an analysis of some of the key issues arising for businesses and property owners when transitioning from an existing business model to the provision of emergency...
Finance Act 2022: Impact on Financial Services Sector
Laura McKeown and Caroline Kealey summarise the key measures in Finance Act 2022 from a financial services perspective....
Finance Act 2022: Changes to Pensions & Pan-European Personal Pension Products
Alison McHugh and Jennifer Dineen discuss the pension changes in Finance Act 2022, along with the new legislation in the Act that deals with the tax treatment of Pan-European Personal Pension Products....
Finance Act Measures Updating R&D Tax Credit, KDB and Digital Games Tax Credit
Damien Flanagan and Cian Smith examine the details of the Finance Act 2022 changes for the R&D tax credit regime, the Knowledge Development Box and the digital games tax credit....
Finance Act 2022: Residential Property Measures
Brendan Murphy outlines the measures in Finance Act 2022 aimed at alleviating the housing crisis, including incentives for renters, landlords, sellers and purchasers....
Finance Act 2022: Disposal of Certain Patent Rights – Amendments to s757 TCA 1997
Karen Grimes and Billy McMahon discuss the amendments to s757 TCA 1997 made by Finance Act 2022 and their possible impact on transactions involving intellectual property....
Share Remuneration: An Alternative Benefit for Employees
Kim Doyle and James McMahon explain the different types of share-based remuneration that companies can use to recruit and retain employees tax-efficiently....
Recent Stamp Duty TAC Determinations: A Review
Amanda-Jayne Comyn discusses two recent decisions on stamp duty by the Tax Appeals Commission (and later the High Court and Court of Appeal) that are topical and of importance for practitioners working...
Residential Zoned Land Tax: Latest Updates and Operational Considerations
Sinead Lew and Aaron Mullan examine amendments to the residential zoned land tax (RZLT) introduced in Finance Act 2022 and outline a number of key practical considerations in relation to the operation...
Editor’s Pages
Issue 1, 2023 Editor’s Pages Published March 29, 2023 in Uncategorized Julie Burke, Editor Table of Contents Back to top Employment Tax Matters: Finance Act 2022 Pat O’Brien provides a summary and...
Policy and Representations Monitor
Issue 1, 2023 Policy and Representations Monitor Published March 29, 2023 in Issue 1, 2023 Lorraine Sheegar, Tax Manager, Tax Policy & Representations, Irish Tax Institute Table of Contents Back to top...
Direct Tax Cases: Decisions from the Irish High Court and Tax Appeals Commission Determinations
Issue 1, 2023 Direct Tax Cases: Decisions from the Irish High Court and Tax Appeals Commission Determinations Published March 29, 2023 in Issue 1, 2023 Mark Ludlow, Senior Associate – Tax, RDJ...
Direct Tax Cases: Decisions from the UK and European Courts
Issue 1, 2023 Direct Tax Cases: Decisions from the UK and European Courts Published March 29, 2023 in Issue 1, 2023 Stephen Ruane, Partner and Leader, Tax Solutions Centre, PwC Ireland Patrick...
International Tax Update
Issue 1, 2023 International Tax Update Published March 29, 2023 in Issue 1, 2023 Louise Kelly, Tax Partner, Deloitte Ireland LLP Claire McCarrick, Tax Senior Manager, Deloitte Ireland LLP Table of Contents...
VAT Cases & VAT News
Issue 1, 2023 VAT Cases & VAT News Published March 29, 2023 in Issue 1, 2023 Gabrielle Dillon, Director – VAT, PwC Ireland Table of Contents Back to top VAT Cases Provision...
Accounting Developments of Interest
Issue 1, 2023 Accounting Developments of Interest Published March 29, 2023 in Issue 1, 2023 Aidan Clifford, Advisory Services Manager, ACCA Ireland Table of Contents Back to top Ten-Year Audits and Sole...
Legal Monitor
Issue 1, 2023 Legal Monitor Published March 29, 2023 in Issue 1, 2023 Philip McQueston, Of Counsel, A&L Goodbody Table of Contents Back to top Selected Acts Signed into Law from 1...
Tax Appeals Commission Determinations
Issue 1, 2023 Tax Appeals Commission Determinations Published March 29, 2023 in Issue 1, 2023 Catherine Dunne, Barrister-at-Law Table of Contents Back to top Published from 1 November 2022 to 31 January...
President’s Pages
The final quarter is always busy for the Institute and its members, and this year was no different. It kicked off with the publication of the Report of the Commission on Taxation...
Chief Executive’s Pages
From the lifting of Covid-19 restrictions and a war on European soil to an energy and cost-of-living crisis, 2022 has not been a year that we could have predicted. Yet, as we...
Tribute to Terry Cooney
Terry was a founder member of the then Institute of Taxation in Ireland and attended the legendary first meeting in the Presbyterian Association Hall on St Stephen’s Green that approved the foundation...
News & Moves
News and moves in the tax community......
Key CAT Compliance Obligations in 2022
Tracey O’Donnell and Lydia McCormack provide an overview of the key compliance obligations for capital acquisitions tax in 2022....
Taxation of Non-Resident Corporate Landlords
Niall McCarthy and Dominic O’Shaughnessy outline the potential Irish tax implications for non-resident corporate landlords and focus on some of the issues arising from the transition to the corporation tax regime for...
Debt Warehousing Scheme: Key Developments and Dates Over the Months Ahead
The Tax Policy & Representations Team in the Irish Tax Institute provide the key developments on the Debt Warehouse Scheme....
Non-EU Imports and Exports: VAT Considerations
Philip Nolan and Emma Galvin consider the VAT compliance implications for Irish businesses of trading in goods with businesses in non-EU, “third”, countries, with a particular focus on import VAT....
VAT on Property Considerations
Richard Concannon and Donal Kennedy give an overview of common issues and pitfalls that can arise from a VAT perspective as part of property transactions....
Exemption from VAT and Medical Services: Who, What and Why?
Gabrielle Dillon considers two recent determinations of the Tax Appeals Commission on VAT and medical services and outlines relevant case law of the Court of Justice of the European Union....
Arderin Distillery: Legitimate Expectation and Judicial Review of Revenue
Lee Squires and Mona Costelloe consider the High Court decision in Arderin Distillery and its impact on judicial review claims against the Revenue involving legitimate expectation issues....
Section 117 of the Succession Act 1965: Who Has a Potential Claim?
Nichola Delaney provides an analysis of the recent decision of Stack J in the case on s117 applications and explores who exactly might qualify as a “child” under the Act....
M&A Landscape Changes, and How Interest Limitation May Mean More Changes
Alan Heuston and James Quirke consider the mergers and acquisitions (M&A) landscape in Ireland, as well as the recent tax provisions and changes in company law that impact on M&A....
Digital Services Tax
Kim Doyle outlines the history of the digital tax debate, the OECD and EU proposals, the current main unilateral DSTs and the next steps expected from the OECD under Pillar One....
Tax Transparency: What Does It Mean for Companies?
Laura Harney and Opeyemi Osunsan outline the tax transparency landscape and key considerations when looking to develop a company’s tax disclosure strategy, in the context of stakeholders’ demanding greater levels of tax...
The Unshell Directive
Michael Raine outlines the requirements of the EU draft Directive, which is designed to discourage the creation of shell undertakings where they are used for improper tax purposes....
Policy and Representations Monitor
Write an excerpt Write an excerpt Write an excerpt Write an excerpt Write an excerpt Write an excerpt Write an excerpt Write an excerpt Write an excerpt ...
Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations
Issue 4, 2022 Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations Published December 8, 2022 in Issue 4, 2022 Mark Ludlow, Senior Associate – Tax, RDJ LLP...
Direct Tax Cases: Decisions from the UK and European Courts
Issue 4, 2022 Direct Tax Cases: Decisions from the UK and European Courts Published December 8, 2022 in Issue 4, 2022 Stephen Ruane, Partner and Leader, Tax Solutions Centre, PwC Ireland Patrick...
International Tax Update
Issue 4, 2022 International Tax Update Published December 8, 2022 in Issue 4, 2022 Louise Kelly, Tax Partner, Deloitte Ireland LLP Claire McCarrick, Tax Senior Manager, Deloitte Ireland LLP Table of Contents...
VAT Cases & VAT News
Issue 4, 2022 VAT Cases & VAT News Published December 8, 2022 in Issue 4, 2022 Gabrielle Dillon, Director – VAT, PwC Ireland Table of Contents Back to top VAT Cases Transfer...
Accounting Developments of Interest
Issue 4, 2022 Accounting Developments of Interest Published December 8, 2022 in Issue 4, 2022 Aidan Clifford, Advisory Services Manager, ACCA Ireland Table of Contents Back to top Russian Sanctions The EU...
Revenue Commissioners’ Update: Reviewing the Effectiveness of the
Co-operative Compliance Framework in Revenue
Issue 4, 2022 Revenue Commissioners’ Update: Reviewing the Effectiveness of the Co-operative Compliance Framework in Revenue Published December 8, 2022 in Issue 4, 2022 Vincent Walsh, Large Corporates Division, Revenue Table of...
Legal Monitor
Issue 4, 2022 Legal Monitor Published December 8, 2022 in Issue 4, 2022 Caroline Austin, Partner, Tax Department, Matheson Table of Contents Back to top Selected Acts Signed into Law 1 August–31...
Tax Appeals Commission Determinations
Issue 4, 2022 Tax Appeals Commission Determinations Published December 8, 2022 in Issue 4, 2022 Tara Duggan, Tax Technical Author, Irish Tax Institute Table of Contents Back to top Determinations of the...
Customs Update – Winter 2022
Issue 4, 2022 Customs Update – Winter 2022 Published December 8, 2022 in Issue 4, 2022 Mark Brennan, Senior Manager, Global Trade & Customs, PwC Ireland John P. O’Loughlin, Partner, Global Trade...
UK and Northern Ireland Tax Update – Winter 2022
UK and Northern Ireland Tax Update - Winter 2022UK and Northern Ireland Tax Update - Winter 2022UK and Northern Ireland Tax Update - Winter 2022...
Editor’s Pages
Issue 4, 2022 Editor’s Pages Published December 8, 2022 in Issue 4, 2022 Table of Contents Back to top Key CAT Compliance Obligations in 2022 Tracey O’Donnell and Lydia McCormack provide an...
Interview with New Irish Tax Institute President, Colm Browne
Colm Browne was inaugurated as the 47th President of the Institute at the AGM on 8 September. Colm is a Tax Director in PwC and is based in Limerick. Before taking up...
Chief Executive’s Pages
At the Institute’s recent Annual General Meeting, Colm Browne was elected as the 47th President of the Institute. Colm joined Council in 2014 and has been on many Institute committees over the...
News & Moves
News and moves in the tax community......
Corporation Tax Return 2021: Focus on Disclosures
Patrick Mulcahy and Ross Duffy set out some of the key disclosure changes to the 2021 Form CT1 (including graphical illustration) with the aim of assisting practitioners through a busy compliance season....
Grid Connections: A Capital Allowances Conundrum
Steven Gardiner analyses a recent Tax Appeals Commission determination that tackles the thorny issue of whether power station grid connection costs qualify for capital allowances....
Interest Limitation Rules: Interpretation and Guidance
Lorraine Mulligan outlines recent Revenue guidance on the ILR and highlights some areas where further clarification would be welcome....
Group Rationalisation Post-Acquisition: Part 1
Úna Ryan and Caroline Kennedy discuss the factors to consider in planning a post-acquisition group restructuring....
Institute Responds to Consultation on Implementing Pillar Two Minimum Tax Rate
Anne Gunnell and Clare McGuinness outline the Institute’s response to the Department of Finance consultation on the implementation into Irish law of the EU Pillar Two Minimum Tax Directive....
DEBRA: The Proposed Debt–Equity Bias Reduction Allowance
Paula Campbell and Chloe O’Hara discuss the European Commission’s proposal for a Directive on creating a debt–equity bias reduction allowance....
The Mobile US Private Client
Brian Broderick considers the tax implications of migrating from the US to Ireland for private clients – both Irish nationals returning home and US nationals with no pre-existing Irish links....
The Analysis of Employees and Contractors in Ireland “Pizzas, Elephants and Uber”
Julie Galbraith and Robert Dever discuss the decision of the Court of Appeal in Karshan (Midlands Limited) t/a Domino’s Pizza v The Revenue Commissioners and its implications for businesses in Ireland....
The Legal Framework for Crypto-Assets
John Breslin and David Sweetman consider the current legal status of crypto-assets in Ireland at common law and the trajectory of crypto-asset regulation in the European Union....
The Tax Framework for Crypto-Assets
Susan Roche, Nicola Sheridan and Ruth Maloney consider the current tax treatment of crypto-assets and transactions in Ireland, across direct and indirect taxes, along with the proposals relating to tax at EU...
Policy and Representations Monitor
Issue 3, 2022 Policy and Representations Monitor Published September 26, 2022 in Regular Features Lorraine Sheegar, Tax Manager, Tax Policy & Representations, Irish Tax Institute Table of Contents Back to top News...
Direct Tax Cases: Decisions from the Irish High Court
Issue 3, 2022 Direct Tax Cases: Decisions from the Irish High Court Published September 26, 2022 in Regular Features Mark Ludlow, Senior Associate – Tax, RDJ LLP Table of Contents Back to...
Direct Tax Cases: Decisions from the UK and European Courts
Issue 3, 2022 Direct Tax Cases: Decisions from the UK and European Courts Published September 26, 2022 in Regular Features Stephen Ruane, Partner and Leader, Tax Solutions Centre, PwC Ireland Patrick Lawless,...
International Tax Update
Issue 3, 2022 International Tax Update Published September 26, 2022 in Regular Features Louise Kelly, Tax Partner, Deloitte Ireland LLP Claire McCarrick, Tax Senior Manager, Deloitte Ireland LLP Table of Contents Back...
VAT Cases & VAT News
Issue 3, 2022 VAT Cases & VAT News Published September 26, 2022 in Issue 3, 2022 Gabrielle Dillon, Director – VAT, PwC Ireland Table of Contents Back to top VAT Cases Rates...
Accounting Developments of Interest
Issue 3, 2022 Accounting Developments of Interest Published September 26, 2022 in Issue 3, 2022 Aidan Clifford, Advisory Services Manager, ACCA Ireland Table of Contents Back to top Charities (Amendment) Bill 2022...
Revenue Commissioners’ Update
Issue 3, 2022 Revenue Commissioners’ Update Published September 26, 2022 in Regular Features Table of Contents Back to top Reminder to Update Your Bank Details on revenue.ie Revenue is reminding customers who...
Legal Monitor
Issue 3, 2022 Legal Monitor Published September 26, 2022 in Regular Features Caroline Austin, Partner, Tax Department, Matheson Table of Contents Back to top Selected Acts Signed into Law 1 May–31 July...
Tax Appeals Commission Determinations
Issue 3, 2022 Tax Appeals Commission Determinations Published September 26, 2022 in Regular Features Tara Duggan, Tax Technical Author, Irish Tax Institute Table of Contents Back to top Determinations of the Tax...
Tax Technology Update – Autumn 2022
Issue 3, 2022 Tax Technology Update – Autumn 2022 Published September 26, 2022 in Regular Features John Curry, Principal, Tax Transformation & Technology, KPMG Table of Contents Back to top “Automation applied...
Customs Update – Autumn 2022
Issue 3, 2022 Customs Update – Autumn 2022 Published September 26, 2022 in Regular Features John P. O’Loughlin, Partner, Global Trade & Customs, PwC Ireland Gavin Williams, Associate, Global Trade and Customs,...
Editor’s Pages
Issue 3, 2022 Editor’s Pages Published September 26, 2022 in Issue 3, 2022 Table of Contents Back to top Corporation Tax Return 2021: Focus on Disclosures Patrick Mulcahy and Ross Duffy set...
Policy and Representations Monitor
Issue 2, 2022 Policy and Representations Monitor Published June 30, 2022 in Issue 2, 2022 Lorraine Sheegar, Tax Manager, Tax Policy & Representations, Irish Tax Institute Table of Contents News Alert Revenue’s...
Direct Tax Cases: Decisions from the Irish High Court and Tax Appeals Commission Determinations
Issue 2, 2022 Direct Tax Cases: Decisions from the Irish High Court and Tax Appeals Commission Determinations Published June 30, 2022 in Issue 2, 2022 Tara Duggan, Tax Technical Author, Irish Tax...
Direct Tax Cases: Decisions from the UK and European Courts
Issue 2, 2022 Direct Tax Cases: Decisions from the UK and European Courts Published June 30, 2022 in Issue 2, 2022 Stephen Ruane, Partner and Leader, Tax Solutions Centre, PwC Patrick Lawless,...