Robert Dever, Gerry Beausang and Brídín Redmond explain what an earn-out is, the structuring issues to be considered, and sellers’ rights and obligations during the earn-out period, in the first article of...
Kim Doyle provides a recap of the order for claiming the various reliefs for trading losses, how these reliefs interact with the relief available for trade and non-trade charges, and how to...
Martin Phelan considers the judgment in this case concerning the availability of group loss relief to a US LLC under the Ireland–US double taxation agreement and s411 TCA 1997....
Emma Arlow provides an overview of the interest limitation rules, specifically the treatment of carried-forward amounts, in addition to commentary on future changes at EU and domestic level....
Junior Chapwanya, Stephanie Curtin and Nicola Carter discuss acquisition structuring, post-acquisition considerations, value creation and exit planning in a follow-up to their article in Irish Tax Review, Issue 3 of 2024....
Cian O’Sullivan provides an analysis of the position regarding the deductibility of royalty withholding tax after recent Tax Appeals Commission determinations....
Anne Hogan and John O’Reilly look at forestry as an investment and examine the taxation of woodlands and forestry, covering all tax heads, and consider relevant Tax Appeals Commission decisions....
Kim Clarke and Eugen Trombitas outline the VAT policy moves made by Ireland to address environmental sustainability and highlight the emerging global trend of jurisdictions using their VAT systems to promote sustainability....
Gabrielle Dillon provides an analysis of the VAT rules and practicalities surrounding the development of property, lettings, the disposal of property subject to lettings, and impact of a change of use to...
Colm Brussels and Olivia Long provide an overview of the recent High Court decision in O’Sullivan v Revenue, which considered the application of the Irish provisions on the time limit for Revenue...
Junior Chapwanya and Stephanie Curtin discuss the key tax considerations at the pre-acquisition stage of a deal in the first article of a two-part series....
Conor Kennedy, in the second article of a two-part series, considers the steps that practitioners should take to satisfy Revenue of the commercial legitimacy of any impugned transactions where tax avoidance is...
Marianne Donaghy and Matthew Greene provide a summary of the exceptions to the requirement for the parties to remain associated in order to avail of stamp duty group relief, as set out...
Charlotte Cumiskey considers the recent High Court decision in the case of Arlum that a write-down in value of sites acquired with debt does not constitute a tax deduction claimed for the...
Eoin Brennan examines a tax appeal that highlights how understanding the nuances of the science test and being prepared for challenges are key to a successful R&D tax credit claim....
Lauren Clabby provides guidance on completing the 2023 Form 11/12, including a review of relevant Finance Act changes and eBriefs published by Revenue....
Justine Murphy discusses the different types of employee share incentive schemes, including their tax implications and reporting obligations, and explains how share valuations play an important role in implementing the schemes. ...
Martin Phelan considers Tax Appeals Commission determination 31TACD2023, where Revenue was found to have breached the taxpayer’s right to a defence under EU law by failing to provide it with its file...
Dara Higgins and Freda Mc Geough provide an overview of the High Court case of Covidien, which examines the right of holding companies to deduct VAT, particularly in the context of corporate...
Adrian Godwin provides an overview of key factors to consider when making personal contributions to pension schemes based on your income, together with a summary of recent changes and anticipated updates in...
Madeline Delaney explains the support, guidance and advice that it can provide to trustees and the professional advisers whom charities engage with. ...
George Thompson and Laura Shanahan provide an overview of the country-by-country (CbC) and public CbC reporting obligations in Ireland, including the information to be provided, timelines for submission and applicable penalties....
Kelly Caffrey explains the key considerations for companies heading into the busy tax filing season....
James Fox and Ray Smyth outline how Irish VAT registration, once straightforward, now presents greater complexity, with increased documentation and scrutiny to combat fraud, affecting both domestic entities and foreign companies...
Emma Lawrence summarises the process by which a new organisation can be established, register as a charity and apply for a charitable tax exemption....
Tony Gilhawley examines the standard fund threshold, including the underlying policy objectives and the implications for both public and private sector pensions....
Alan Heuston and Ian Hanrahan review the operation of entrepreneur relief and retirement relief in the context of a disposal of shares and outline the interaction of the two reliefs in practice....
Mairéad Hennessy discusses the workings of the VAT-on-property Capital Goods Scheme, providing examples that illustrate the application of the rules in certain scenarios and discussing practical challenges in operating the regime....
Conor Kennedy, in a two-part series of articles, considers the steps that practitioners should take to satisfy Revenue of the commercial legitimacy of any impugned transactions where tax avoidance is not the...
Caitríona Moran outlines the UK Budget announcement of the abolition of the “non-domiciled ” remittance-based tax regime and its replacement with a four-year Foreign Income and Gains residency regime, due to take...
Dearbhla Cunningham considers a recent High Court case concerning the meaning of “full and true disclosure” in the context of the four-year time limit on Revenue’s power to raise assessments....
Harry Harrison, Chloe Fox and Paul McKenna provide a high-level overview of the GloBE rules, drawing attention to the areas of particular importance and seeking to simplify insofar as possible these very...
Sybil Smyth outlines the Finance (No. 2) Act 2023 changes that could have a significant impact on financial services taxpayers, particularly those engaged in leasing activities....
Fionnuala Hynes, Danielle Cunniffe and Aidan Lucey explain the new provisions on joint audits introduced by Finance (No. 2) Act 2023, the cross-border tax dispute-resolution mechanisms available and how taxpayers can best...
Damien Flanagan and Cian Smith examine the details of the Finance (No. 2) Act 2023 changes to the R&D tax credit regime in Ireland....
Ian Collins and Arek Rojek outline recent changes to the digital games corporation tax credit and suggest possible updates in the future....
John Cuddigan reviews the Finance Act changes to s598 and s599 TCA 1997, with particular focus on the new cap that will apply to disposals of qualifying assets from 1 January 2025....
Julia Considine examines the changes to CAT brought in by Finance (No. 2) Act 2023 with particular focus on the new reporting requirement for “close relative” loans and the impact of clawback...
Paul Nestor provides an overview of the changes introduced to these reliefs by Finance (No. 2) Act 2023 to conform with amendments to the EU General Block Exemption Regulation....
Alison McHugh and Brian O’Malley consider the legislation introducing this new CGT relief, the objective of which is to encourage investment in innovative start-up businesses that are SMEs....
Brendan Murphy examines the changes to s664 TCA 1997, which provides for tax relief on leasing farmland, introduced by s33 of Finance (No. 2) Act 2023....
Robert Dever, Julie Galbraith and Laura Ellen Ford provide an overview of the Supreme Court decision in The Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino’s Pizza [2023] IESC 24....
Niamh Barry gives an overview of the enhanced reporting requirements for employers that are due to take effect from 1 January 2024, including preparation tips and highlights from the recently published Revenue...
Kevin Smith and Bernadine Dooley provide an overview of the offshore funds legislation in Ireland and focus on some of the key distinctions and difficulties for taxpayers and advisers in navigating the...
Charlotte Cumiskey gives an overview of the essential tax obligations of both individual and corporate non-resident landlords in Ireland....
Nicola Sheridan and Ruth Maloney explain the CESOP Directive, which will come into effect from 1 January 2024 and will require payment service providers to maintain electronic records on cross-border payments and...
Aoife Murray and Priyanka Asopa cover some recent developments in Ireland that are relevant to taxpayers operating in the financial services space....
Adrian Walker gives an overview of the changes in filing requirements for FY2022 claims under the R&D tax credit scheme....
Alison McHugh and Andrea McNamara set out the circumstances in which discretionary trusts may be used for the purpose of protecting assets and/or individuals....
Dearbhla M. Cunningham discusses the errors that may be reviewed by the High Court and the standard of review applied to them in an appeal against an unfavourable determination of the Tax...
Gráinne Duggan answers the questions that she is asked most often about bringing a tax appeal to the Tax Appeals Commission....
Mark Bradshaw An introduction to Revenue’s development of an online Special Assignee Relief Programme portal (eSARP). This development will modernise the existing SARP process....
Pat O’Brien outlines the background to and early years of an independent tax system in the new Irish State on the 100 year anniversary of its foundation....
George Thompson, Helen McGee and Pedro de Polignac outline how new legislation adopting the “authorised OECD approach” to the attribution of profits to branches of non-Irish-resident companies has been introduced, bringing additional...
Sybil Smyth provides an overview of the recently released Revenue guidance on the classification of foreign entities....
Jane Hughes explains some of the tax considerations for investors, as well as practical issues that may arise in returning a clawback of EII relief from a compliance point of view....
Colin Forbes and Jackie Coughlan consider the tax implications of remote working and provide an overview of recent Revenue updates relating to globally mobile employees....
Noreen Lynch offers a six-step framework to assist newly qualified CTAs with structuring tax research....
Feargal Kenzie takes a look at the key considerations for tax practitioners arising from the revised Code of Practice for Revenue Compliance Interventions, effective from 1 May 2022....
Alan Heuston and James Quirke discuss the decision in Cintra Infraestructureas Internacional SLU v The Revenue Commissioners [2023] IEHC 72, where the High Court upheld a Tax Appeals Commission determination that the...
Eoin Tobin discusses the judgment of Twomey J in the High Court case of Egan, which considered the legal effect of a disclaimer in favour of a third party for the first...
Martin Phelan and Fiachra Ó Raghallaigh provide an overview of the UK First-tier Tribunal’s decision in Burlington Loan Management v HMRC, which sets a high bar for tax authorities’ proof that a...
Conor Kennedy considers how practitioners should prepare for tax appeal hearings, in particular, the fundamental requirement to ensure that all evidence is made available to an Appeal Commissioner....
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....
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....
Kelly Caffrey explains the key considerations to be taken into account for the 2022 corporation tax compliance cycle. ...
Angela Fleming and Yvonne Diamond provide a practical guide for corporation tax filers that explains disclosure requirements on the CT1 regarding interest limitation rules....
Siobhán O’Moore and Adrian Farragher outline the main CAT and CGT compliance issues that should be considered by both individuals and companies....
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...
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....
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....
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....
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...
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....
Úna Ryan and Caroline Kennedy discuss the anti-avoidance provisions that apply to group restructurings and reorganisations....
Pat O’Brien provides a summary and analysis of the key provisions in the Finance Act 2022 relating to employment tax matters....
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....
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...
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...
Laura McKeown and Caroline Kealey summarise the key measures in Finance Act 2022 from a financial services perspective....
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....
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....
Brendan Murphy outlines the measures in Finance Act 2022 aimed at alleviating the housing crisis, including incentives for renters, landlords, sellers and purchasers....
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....
Kim Doyle and James McMahon explain the different types of share-based remuneration that companies can use to recruit and retain employees tax-efficiently....
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...
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...
Tracey O’Donnell and Lydia McCormack provide an overview of the key compliance obligations for capital acquisitions tax in 2022....
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...
The Tax Policy & Representations Team in the Irish Tax Institute provide the key developments on the Debt Warehouse Scheme....
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....
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....
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....
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....
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....
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....
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....
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...
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....
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....
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....
Lorraine Mulligan outlines recent Revenue guidance on the ILR and highlights some areas where further clarification would be welcome....
Úna Ryan and Caroline Kennedy discuss the factors to consider in planning a post-acquisition group restructuring....
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....
Paula Campbell and Chloe O’Hara discuss the European Commission’s proposal for a Directive on creating a debt–equity bias reduction allowance....
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....
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....
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....
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...
Lauren Clabby highlights areas that practitioners need to be mindful of when preparing and filing 2022 personal tax returns, with a particular emphasis on the complexities added by the Covid-19 pandemic....
Brendan Murphy and Kevin Donovan outline the key considerations for tax advisers and companies regarding the submission of corporation tax returns for accounting periods ending in 2021....
Siobhán O’Moore and Adrian Farragher outline the main CAT and CGT compliance issues that should be considered by both individuals and companies....
Sinéad Leahy and Sinéad MacDonnell explain recent changes in VAT reporting requirements and outline how taxpayers can meet the requirements and minimise risks by implementing robust internal processes and controls....
Emma Arlow analyses the impact of the new interest limitation rules on SMEs at different stages of their lifecycle and provides a detailed worked example of how the rules apply to interest...
Patrick Duggan considers highlights from the UK 2022 Spring Statement and some previously announced tax measures that came into force on 1 April 2022 and contemplates what might lie ahead in the...
Catherine Murray and Paul Lombard discuss Ireland’s current commitments to combating climate change and how tax can be used to encourage green investment in Ireland while mitigating the risks of climate change....
Nathan Doherty and Robert Henson highlight some of the direct tax impacts of Brexit for businesses, particularly for groups with UK companies in their structure....
Brendan Slattery, Martina Firbank and Eleanor MacDonagh examine the new residential zoned land tax introduced by the Finance Act 2021 and consider its potential impact on property owners and developers....
Conor Kennedy highlights the assortment of tax issues and the difficulties faced by practitioners in taking an appeal before the Tax Appeals Commission....
Philip McQueston and Rebecca Dorrington review OECD and EU mandatory arbitration measures aimed at improving international tax dispute resolution....
Mark Barrett explains the changes in Revenue’s new Code of Practice, which will “go live” on 1 May, and outlines the Institute’s work to inform and assist members in the transition to...
Mary Healy provides a summary of the ITI’s key representations on these developments in our engagement with Revenue over the last eight months....
Sarah Waters provides an overview of Revenue’s new Compliance Intervention Framework....
Harry Harrison and Seán McCarthy outline of some of the key aspects of the reverse hybrid legislation, as well as changes to the existing anti-hybrid legislation, recently introduced by Finance Act 2021....
Ethna Kennon and Patrick Whelan outline the case law behind FA 2021’s abolition of suppliers’ entitlement to reclaim VAT that was previously accounted for in respect of non-refundable customer deposits....
Sarah Meredith provides a summary of the Finance Act 2021 changes from a corporate tax perspective....
Paul Nestor explains the FA 2021 changes to the Employment Investment Incentive, the Employment Wage Subsidy Scheme and income tax warehousing for proprietary directors....
Julia Considine outlines the amendments to capital acquisitions tax and stamp duty made in Finance Act 2021....
Susan Roche, Antoinette Ryan and David Gillen provide an overview of DAC 7 provisions recently introduced into Irish legislation as part of Finance Act 2021 and highlight some key areas for consideration....
Emma Arlow provides an overview of the recently enacted interest limitation rules and their scope and explains the steps involved in applying the restriction....
Dominic McNeill, Ciaran Dornan and Dan McSwiney discuss the exclusion from the application of the basic rules on transfer pricing in Ireland that is provided in respect of certain wholly domestic transactions...
Aileen Keogan explains the CRBOT – a new register for Irish trusts arising from the EU’s continuing effort to combat money laundering – and discusses what trusts should be registered, how to...
Ian Collins, Arek Rojek and Adrian Dunne provide an insight into the new digital games tax credit, which was introduced by Finance Act 2021 and is awaiting commencement pending European Commission approval....
Danielle Cunniffe and Kevin Quinn discuss their experience of the TAC, which is blazing a trail in the efficient and effective management of tax appeals, and highlight some areas of focus for...
Louise Kelly and Anthony O’Halloran consider the US tax reform proposals being considered by the Democratic Party, as President Biden seeks to act on his election proposals regarding a retooling of the...
Anne Gunnell and Clare McGuinness examine the position adopted by Ireland towards the OECD July Statement, the subsequent public consultation on the proposals, and the rationale for the change in Ireland’s position...
John P. O’Loughlin, David Lusby and Avril McDowell discuss the indirect tax challenges for businesses stemming from the new EU VAT e-commerce package and Brexit....
Amanda-Jayne Comyn and Theresa Ryan explain the filing requirements for CGT and CAT, outlines the implications of failure to file a return or failure to disclose the requisite information....
Tina Quealy and Clare Foley review the SA2 CAT form since its inception in September last year....
Kieran Binchy provides a case report on Perrigo Pharma International DAC v McNamara [2020] IEHC 552, setting out why Perrigo’s claim for legitimate expectation was unsuccessful....
Ursula Mathews and Pat Mahon look at recent developments in Ireland and abroad after the Uber case in the UK and consider where we now stand in the employed vs self-employed debate....
Michael Shovlin provides an overview of some of the main non-tax legal issues that arise when advising on the establishment and operation of share schemes in Ireland....
Ingrid O’Gorman and Cian O’Donovan review the changes to the local property tax regime introduced by the Finance (Local Property Tax) (Amendment) Act 2021....
Áine Flynn, Director of the Decision Support Service, highlights the key features of thisÁine Flynn, Director of the Decision Support Service, highlights the key features of this significant reforming Act, the commencement...
Jacky Fox outlines the steps required by firms of every size to measure their security capabilities against increasingly sophisticated cyber threats....
Lauren Clabby provides an overview of matters to consider before preparing 2020 tax returns....
Brendan Murphy and Kevin Donovan discuss the key changes and considerations to be kept in mind when filing corporation tax returns for accounting periods ending in 2020....
Ronan Finn, Ashita Popat and George Thompson summarise the key issues that taxpayers need to be aware of when considering their transfer pricing documentation obligations for FY2020 and future years....
Aidan Clifford explains some of the accounting issues faced by businesses as a result of the pandemic, including impairments, provisions, revenue recognition and onerous contracts....
Michelle Dunne provides a summary of the provisions contained in the Finance (Covid-19 and Miscellaneous Provisions) Bill 2021, with the exception of the stamp duty measures....
Lynn Cramer and Grainne O’Loughlin discuss the recent Finance Act provisions that introduced an increase in the stamp duty rate on acquisitions of more than ten residential units and set out some...
Emer Dowling provides an overview of the direct tax implications of examinership, Small Company Administrative Rescue Process (SCARP), receivership and liquidation....
Fiona Carney explains the important updates made to Revenue’s Tax and Duty Manual on DAC 6, including new guidance on the hallmarks in Category C....
Patrick Duggan summarises the key measures in the UK Budget announced on 3 March 2021 and reflects on what may lie ahead as we move towards the 2021 Autumn Statement....
Shane Wallace, Jessica Hayes and Brian Mullane discuss the Irish CGT charge for non-residents in light of the recent Tax Appeals Commission determination 75TACD2021....
Marie-Claire Maney outlines the positive developments of the TAC over the past year and explains the plans for the future....
Ken Hardy, Damien Flanagan and Stephen Brennan examine digital gaming tax incentives in other jurisdictions and explore Ireland’s options as an up-and-coming hub, given the new digital gaming tax credit that is...
Anna Holohan and Séamus Kennedy discuss the recent reforms to the investment limited partnership fund vehicle and related tax considerations....
Aileen Daly and Joanne O’Sullivan summarise the key aspects of the framework, which was updated in December 2020, and outline how it operates in practice....
This update from Revenue highlights the importance of data quality in payroll reporting....
Tomás Bailey and Rachel O’Sullivan discuss the recent decision of the Court of Appeal in this case, which clarifies the principles applicable in determining the jurisdictional scope of the Tax Appeals Commission....
Martin Phelan and Patricia McCarvill discuss this Tax Appeals Commission determination, which considered whether, for group relief purposes, an LLC is a “body corporate” and whether it is resident for the purposes...
Pat O’Brien explores the history of PAYE in Ireland since its controversial introduction in 1960 despite concerns of the Revenue Commissioners....
Paul Nestor provides a summary of the provisions in FA 2020 relating to supports such as debt warehousing, the Employment Wage Subsidy Scheme and the Covid Restrictions Support Scheme....
Dermot Donegan and Denise Corrigan explain the VAT e-commerce changes that will take effect from 1 July 2021....
Gabrielle Dillon outlines the legislation that forms the basis of the VAT rates applicable in Ireland and highlights recent case law and legislative changes....
Tiiu Albin Pereira and Chloe O’Hara summarise recent EU tax policy objectives and how they interact with changes in the global tax environment and consider the tax policy measures that Ireland is...
Anne Gunnell, Clare McGuinness and Lorraine Sheegar outline the most recent responses of the Institute’s Tax Policy and Representations team to consultations by the Department of Finance and the European Commission....
Paddy Doherty and Michelle McKinley provide an overview of the UK corporate interest restriction rules introduced in April 2017 in response to BEPS Action 4 and consider some of the practical issues...
Carol Hogan explains the options available to those seeking the orderly and tax-efficient transfer of assets/wealth to beneficiaries....
Philip McQueston and Gwen Lehane consider the legal basis for and recent case law on the exchange of information between tax authorities....
Eleanor MacDonagh and Deirdre Barnicle consider the provisions contained in Finance Act 2019 relating to Irish real estate funds, the background, the perceived drivers, the issues and published Revenue guidance thereon....
Nina E. Olson outlines the continuum of different behaviour and causes that can comprise non-compliance and argues that there is a consequent need for more precision in the use of the term...
Hugh Owens explains the operation of the Fair Deal Scheme, which provides financial support towards the cost of nursing home care....
John O’Loughlin and Paul Rodgers give an overview of the EU–UK Trade and Cooperation Agreement, explain what it means from a customs and trade perspective, and outline what companies need to do...
John Stewart considers the impact of Brexit for cross-border traders, including the VAT treatment of supplies of goods and services, the non-application of certain VAT simplifications, VAT on imports and VAT recovery....
Kim Doyle and Lorraine Nelson focus on the EU–UK Trade and Cooperation Agreement and some of the key direct tax and social security changes arising as a result of Brexit....
Rachel Fox and Caitriona Moran explains the changes made by Finance Act 2020 to ensure that the post-Brexit migration of certain Irish shareholdings from CREST to the Euroclear central securities depository on...
Frank Mitchell considers the imbalance in the interest rates applicable to tax overpayments and underpayments, which has been added to by s960GA of Finance Act 2020....
Anna Holohan outlines a selection of topics in Finance Act 2020 – other than the headline items – that will be relevant to specific sectors and taxpayers and that illustrate the continuing...
David Rodgers provides a summary of and comment on the changes to capital acquisitions tax, capital gains tax and stamp duty introduced by Finance Act 2020....
Senan Kavanagh and Jennifer Upton discuss the latest changes to HMRC’s Making Tax Digital for VAT regime and the expansion of Making Tax Digital to other taxes....
Marie Flynn and Sarah Kirwan provide an overview of the valuation of private companies and shareholdings for tax purposes and outline the pitfalls/key points to consider in relation to various transactions....
Eoin Clifford considers the impact of the recent Supreme Court decision in this case on the question of statutory versus purposive interpretation of tax statutes....
James Burke considers the requirements for tax relief under s192A TCA 1997 relating to payments made under termination agreements, in light of three recent Tax Appeals Commission determinations....
Anne Gunnell and Lorraine Sheegar outline the Institute’s response to the OECD public consultation on Pillar One and Pillar Two Blueprints....
Information on the the upcoming deadline and requirements for reclaiming VAT under the government’s scheme...
David Fennell details the recently published Revenue guidance on DAC 6....
Florita Dolly provides details of the new measures introduced in the Financial Provisions (Covid-19) (No. 2) Act and how they affect both individuals and companies....
Amanda-Jayne Comyn provides an overview of tax and legal issues that arise on the breakdown of a formal relationship between married couples, civil partners and cohabitants....
Paul Morris addresses matters relating to the CG50 clearance procedure, outlining real-life scenarios where clearance is needed that advisers might not immediately think of....
Suzann McDonnell provides a step-by-step guide to use when considering the impact of the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting...
Dermot Donegan and Denise Corrigan of Revenue answer key questions on the e-commerce VAT changes coming on 1 July 2021....
James Fox and Ben Kelly consider the challenges that businesses face in keeping up to speed with VAT compliance requirements after the introduction in January 2020 of the “Quick Fixes”, as well as...
Anne Gunnell and Mary Healy outline developments since Revenue’s reorganisation of its operational divisions...
Paul McNamara considers the recent decision in this UK High Court case, which provides some important additional guidance for purchasers on best practice for making claims under warranty and indemnity provisions in transaction...
Emer Joyce outlines the changes to the 2019 Form 11 and explains the issues to bear in mind when completing it...
Deirdre Hogan and Katie Barbour consider the unilateral implementation of DST at country level in the absence of agreement on a global/EU coordinated approach and its impact on companies in the digital sector...
Paul Dunlea revisits the fundamentals of how Case V rental income is calculated, identifies the expenditure that continues to be tax-deductible and highlights some of the areas in which difficulties can arise in...
Úna Ryan explains taxpayers’ obligations ahead of the capital acquisitions tax pay and file deadline...
Gabrielle Dillon highlights some of the implications that can arise from a VAT perspective when the landlord–tenant relationship breaks down or is under renegotiation and provides guidance to help counteract possible pitfalls...
Colm O’Callaghan and Danielle Grant consider the impact of Covid-19 on business and the potential formal and informal debt restructuring solutions that may be needed to restart businesses towards the end of this...
Anne Gunnell outlines the key representations that the Institute has made to Revenue, the Department of Finance, the Department of Employment Affairs and Social Protection, and the Tax Appeals Commission during this...
Áine O’Hare and Charlotte Knaggs provide a summary of the key tax changes announced in the UK 2020 Budget and an overview of measures announced in the Chancellor’s Summer Statement...
Patrick Harney and Nicola Simmons consider how UK tax applies across the life cycle of property ownership, given that many Irish people own UK property owing to the proximity of, and socio-economic...
Siobhán Corbett provides an overview of the range of issues that should be considered when advising clients on their estate plan, with particular emphasis on opportunities in an economic downturn...
Emmet Scully gives an analysis of the key provisions in s31C SDCA 1999, which imposed the 7.5% rate of stamp duty on shares deriving their value form non-residential property, highlighting key points from...
Carol Lynch and Ben Twomey consider the customs procedures that need to be established by businesses ahead of the new reality of trading with post-Brexit Britain...
Clare Wardell and Ian Collins set out the updates to Revenue’s R&D tax credit guidelines stemming from the Finance Act 2019 changes and consider the impact on taxpayers who are making R&D...
Harry Harrison and Diarmuid McGarry provide an update on the application of the Irish anti-hybrid legislation introduced in Finance Act 2019, following on from the publication of Revenue guidance in July 2020...
Kate O’Toole and Vincent McCullagh consider the recent Revenue Tax and Duty Manual “VAT Deductibility for Holding Companies” and explore the main provisions of the rules and the complexities faced by such companies...
Gavin O’Flaherty updates practitioners on the adoption of e-signature during the Covid-19 crisis and passes on some of the lessons learned to date...
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Disclaimer The Irish Tax Institute can accept no responsibility for the accuracy of contributed articles or statements appearing in this publication, and any views or opinions expressed are not necessarily subscribed to by the Institute. No responsibility for loss or distress occasioned to any person acting or refraining from acting as a result of the material in this publication can be accepted by the authors, contributors or publisher. Following publication of an article or other feature, it may happen that additional information or a correction will later be published so the reader is advised to refer to subsequent issues.
