Editor's Summary - Issue 3, 2024
Amanda-Jayne Comyn, Circulo
Editor
Tax in Deals: Beyond Mergers and Acquisitions: Part 1
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.
Possible Impact of Anti-Avoidance Measures on Business Decisions: Part 2
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 not the primary motivation.
Stamp Duty Group Relief: Requirement to Remain Associated
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 in both legislation and the Revenue Tax and Duty Manual.
When All Is Forgiven: High Court Ruling on s87(1) TCA 1997
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 debt for the purposes of s87(1) TCA 1997.
Review of the TAC Determination on R&D Tax Credit Science Test
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.