Offshore Funds: A Case for Simplification?

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...

Taxation of Non-Resident Landlords

Charlotte Cumiskey gives an overview of the essential tax obligations of both individual and corporate non-resident landlords in Ireland....

CESOP: New EU Tax Information Reporting Requirements

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...

Disclaimers: Recent Case Law Issues

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...

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....

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...

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....

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...

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...

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....

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....

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....

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 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...

Preparing for Pay and File 2022

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....

Relevant VAT Compliance Issues 2022

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....

Interest Limitation Rules: Key Issues for SMEs

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...

The Role of Tax in Combating Climate Change

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....

Residential Zoned Land Tax: Under the Legal Lens

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....

The Tax Appeal Process

Conor Kennedy highlights the assortment of tax issues and the difficulties faced by practitioners in taking an appeal before the Tax Appeals Commission....

Transfer Pricing: Domestic Exclusion

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...

Tax Appeals Commission: A More Appealing Process

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...

Tax Compliance and the Capital Taxes

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....

Perrigo and the €1.6 Billion Assessment

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....

Local Property Tax: Back to Basics

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....

Cybercrime: Know Your Enemy

Jacky Fox outlines the steps required by firms of every size to measure their security capabilities against increasingly sophisticated cyber threats....

The Susquehanna Case – Group Relief s411 TCA 1997

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...

European Union: Update on Tax Reform Landscape

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...

Institute Responds to Four Tax Policy Consultations

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....

IREFs: Where We Are Now…

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....

The Fair Deal Scheme

Hugh Owens explains the operation of the Fair Deal Scheme, which provides financial support towards the cost of nursing home care....

VAT Implications of Brexit

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....

Brexit: The Other Matters to Consider

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....

Finance Act 2020: Post-Brexit Share Migration

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...

The Mysterious World of Valuations

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....

Relationship Breakdown: Tax Implications

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....

Capital Gains Tax Clearance

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....

A Practical Approach to the Multilateral Instrument

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...

Digital Services Tax: When Will It Byte?

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...

Back to Basics: Case V Income – Rules of the Road

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...

Corporate Debt Restructuring

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...

Exploring Estate-Planning Opportunities

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...

Brexit: Where Do We Stand Now?

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...

Anti-Hybrid Legislation: Update on Revenue Guidance

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...

VAT Recovery for Holding Companies

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...