ArticleCJEU Upholds The Supremacy Of Legal Professional PrivilegeCJEU again upholds the supremacy of legal professional privilege over national disclosure requirements of taxpayer information pursuant to DAC 6...IrelandTaxArthur Cox
ArticleInDisputes: Irish Tax Appeals Commission Achieves Continued Efficiencies Against Ever Increasing ComplexityThe recently published annual report of the Tax Appeals Commission ("TAC") for 2024 offers valuable insights into the impressive performance of TAC. IrelandTaxMatheson
ArticleInDisputes: OECD APA Best Practices In IrelandIreland has had a formal APA programme in operation since 2016, and APAs were entered into by Ireland for many years prior to the introduction of the Programme. IrelandTaxMatheson
ArticleInDisputes Series: High Court Clarifies Admissibility Of Appeal TranscriptsThe Court examined Revenue's request for the inclusion of the transcript, focusing on whether the transcript was necessary to the Court's adjudication of the ‘points of law' being appealed. IrelandTaxMatheson
ArticleInDisputes – Evaluating Targeted Anti-Avoidance In Irish Tax AppealsThe Irish Tax Appeal Commission (the "TAC") recently rejected a taxpayer's (the "Appellant") claim for capital gains tax ("CGT") deferral under section 586 TCA. This decision offers an insight into the approach of the TAC in considering targeted anti-avoidance provisions under Irish tax legislation.IrelandTaxMatheson
ArticleInterest Taxation Reform: An Overview Of The Phase One Feedback StatementOn the 21 November, the Department of Finance issued its Feedback Statement containing a Strawman Proposal on "Phase 1 of Reform of Ireland's Taxation Regime for Interest". IrelandTaxArthur Cox
ArticleThe Roundtable June 2022Ireland's tax regime exists within the framework of an international series of agreements, including, notably, the OECD and the EU.IrelandTaxMaples Group
ArticleTaxand: Strong M&A Activity Forecast For H2 After Fast Start To 2021Taxand's 2021 Guide provides commentary and insights into the tax treatment of global M&A deals.IrelandCorporate/Commercial LawWilliam Fry LLP
ArticleCJEU Judgment On UK CFC Rules Contrasts With Apple JudgmentThe European Commission Decision concerned an exemption within the UK CFC rules known as the ‘group financing exemption'. Under the UK CFC rules, a CFC charge applies...IrelandTaxArthur Cox
ArticleInDisputes Series: Amending A Tax Appeal – Recent High Court ClarityIn the recent case of Express Motor Assessors Limited v Revenue Commissioners the High Court clarified the process for amending appeals against determinations of the Tax Appeals Commission.IrelandTaxMatheson
ArticleInDisputes – Fair Procedures And The Charter: Application In Tax DisputesThe High Court decision in Hamill v the Revenue Commissioners examines when taxpayers can invoke EU Charter protections in Irish tax disputes, particularly regarding fair procedures and access to information during VAT assessments.European UnionTaxMatheson
ArticleCross-Option Agreements – Safeguarding The Future Of The Family BusinessWhen family members run a business together – whether as partners or shareholders in a family company – a critical question is, what should happen in the unfortunate circumstances...IrelandFamily and MatrimonialArthur Cox
ArticleInDisputes: Revenue Reject Tax DecisionThe Irish Revenue Commissioners ("Irish Revenue") updated their Tax and Duty Manual "Part 5: Section 31D - Cancellation schemes of arrangement" in May 2023 to make reference...IrelandTaxMatheson
ArticleInDisputes: The Importance Of Expert Evidence In Tax DisputesExpert evidence is often required for the purposes of establishing issues of fact (e.g. foreign law, accounting, economics, valuation, etc) in tax cases before the Tax Appeals Commission...IrelandTaxMatheson
ArticleIrish Revenue Commissioners Annual Report 2025: Key Insights For MNEsThe Irish Revenue Commissioners' 2025 Annual Report reveals significant developments in international tax dispute resolution and transfer pricing certainty mechanisms.IrelandTaxMatheson
ArticleRevenue Publishes New Guidance On Employee Misclassification CasesThe Revenue Commissioners have issued a new guidance note offering employers a final opportunity to address misclassification issues following the Supreme Court decision...IrelandTaxAddleshaw Goddard
ArticleSARP – 2023 UpdateThe Special Assignee Relief Programme ("SARP") was introduced in 2012 to provide a targeted income tax relief for eligible employees assigned to work in Ireland by their employer companies.IrelandTaxMatheson
ArticleShare Option Gains To Be Taxed Through Payroll From 1 January 2024Finance (No. 2) Bill 2023, which was published last week, provides that, from 1 January 2024, employers will be required to withhold Irish payroll taxes and charges from gains arising on the exercise of share options.IrelandTaxMatheson
ArticleThe CJEU Draws A Line Under The Apple State Aid SagaThe Court of Justice of the European Union (CJEU), sitting as the Grand Chamber has handed down its judgment in the Apple case.IrelandTaxArthur Cox
ArticleTax Credits A Significant 'pull Factor' For Multinationals Operating In Ireland2022 was another year when major changes affecting global tax rules were agreed and as a result the tax landscape in Ireland is likely to undergo a material overhaul from 1 January 2024. IrelandTaxMatheson