Amanda-Jayne Comyn, Editor

Editor's Summary - Issue 4, 2024

Amanda-Jayne Comyn, Circulo
Editor

The Legal and Taxation Aspects of Earn-Outs: Part 1

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 a two-part series. This is also available as an Audio Article.

Trading Losses and Charges on Income: The Different Avenues to Tax Relief

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 claim relief.

The Susquehanna Case: A High Court Reversal

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.

Interest Limitation Rules: Treatment of Carry-Forwards and Potential Future Changes

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.

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Feature Articles

The Legal and Taxation Aspects of Earn-Outs: Part 1

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...

The Susquehanna Case: A High Court Reversal

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....

Tax in Deals: Beyond Mergers and Acquisitions: Part 2

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....

Deductibility of Royalty Withholding Tax

Cian O’Sullivan provides an analysis of the position regarding the deductibility of royalty withholding tax after recent Tax Appeals Commission determinations....

Taxation of Woodlands and Forestry in Ireland

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....

VAT and Sustainability

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....

VAT on Property Scenarios

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...

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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.