Amanda-Jayne Comyn, Editor

Editor's Summary - Issue 3, 2025

Amanda-Jayne Comyn, Editor

Navigating Transfer Pricing in an AI-Driven Tech Landscape

Rustom Dalal and Kevin Norton outline how businesses should understand their AI value-chain to assess the impact on cost allocation and profit attribution. This article is also available on your favourite podcast app, search Irish Tax Review on Spotify, Apple Podcasts, and Soundcloud.

Resetting EU Tax: The Spotlight Turns to Ireland Amid Challenge and Change

Chloe Fox and Kate Glasheen provide an overview of the latest tax policy developments and legislative proposals by the European Commission, which include using tax as a tool to drive broader EU priorities.

RCT for Non-Resident Companies

Kevin Donovan provides a review of relevant contracts tax for non-resident companies, including cash-flow implications and common issues encountered.

Revenue Commissioner’s Update: Common Errors in Research and Development Tax Credit Claims

Marie Doody highlights the common errors encountered when completing the R&D panels of the CT1 return for 2024 and underscores the critical importance of adhering to the legislative requirements under the updated R&D tax credit regime.

The Taxation of Damages and Settlement Payments

Trish McCarvill explains the taxation of damages and settlement payments, including personal injury exemptions; employment law awards; revenue vs capital analysis; deductibility for the defendant; the Gourley principle; warranty and indemnity payments; and VAT.

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Martin Lambe

Chief Executive’s Page

The Institute’s Annual General Meeting took place on 4 September, and Shane Wallace became our 50th President. Shane has been on Council since 2015 and has served on a number of Committees...

Regular Features

Feature Articles

RCT for Non-Resident Companies

Kevin Donovan provides a review of relevant contracts tax for non-resident companies, including cash-flow implications and common issues encountered....

The Taxation of Damages and Settlement Payments

Trish McCarvill explains the taxation of damages and settlement payments, including personal injury exemptions; employment law awards; revenue vs capital analysis; deductibility for the defendant; the Gourley principle; warranty and indemnity payments...

Tax Policy as a Driver of Ireland’s Energy Transition

Brendan Coleman, Sarah Cahill and Sarah Gleeson explore how Ireland can leverage targeted tax policy to drive investment, innovation and compliance in renewable energy, supporting decarbonisation goals and economic growth, drawing on...

Taxpayer Rights: A Look at Revenue’s Customer Charter

Gráinne Duggan and Niamh Ryan consider Revenue’s updated Customer Charter, highlighting its role in fostering trust and transparency while noting its non-legally binding nature and limited effectiveness in safeguarding taxpayers’ rights....

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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.