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  • Article

    Double Taxation: Revenue Issue New Guidelines On Correlative Adjustment Claims

    The Irish Revenue Commissioners ("Revenue") have recently published a new tax and duty manual containing guidelines for correlative adjustment claims under Ireland's double tax treaty network ("CA Guidance").
    IrelandTax
    Matheson
    Matheson
  • Article

    Public Country By Country Reporting Update

    The EU Directive on public country by country reporting of financial and tax information was published on 1 December 2021.
    European UnionTax
    Arthur Cox
    Arthur Cox
  • Article

InDisputes: Section 192A TCA – Some Welcome Clarity From The Irish High Court

As discussed in our 2023 Irish Tax Review article, there have been a number of recent Tax Appeal Commission (TAC) determinations that created a lack of clarity regarding the application of section 192A ...
IrelandEmployment and HR
Matheson
Matheson
  • Article

    The DAC Recast – Delivering Meaningful Tax Simplification

    The European Commission has proposed consolidating nine separate Directives on Administrative Cooperation into a single recast directive, aiming to simplify the EU's tax information exchange framework while maintaining transparency. However, the proposal faces significant challenges including the incorporation of previously rejected "Unshell" provisions, the requirement for unanimous approval from all 27 Member States, and questions about whether the consolidation will deliver meaningful simplification for
    European UnionTax
    Matheson
    Matheson
  • Article

    Budget 2021 – A Response To Challenging Times

    Before the Minister for Finance, Paschal Donohue, and the Minister for Public Expenditure and Reform, Michael McGrath, had risen from their seats to deliver the joint Budget 2021, the media had already extensively reported on many of the measures included.
    IrelandStrategy
    RDJ LLP
    RDJ LLP
  • Podcast

    One Rulebook For 27 Markets: EU Inc And The Future Of European Company Law (Podcast)

    Against a backdrop of sustained political pressure to address Europe’s innovation and competitiveness gap, the European Commission has published its long-anticipated legislative proposal for an EU-wide corporate legal form, commonly referred to as “EU Inc”. The proposal forms the centrepiece of a new “28th regime” corporate legal framework, introducing a harmonised EU-wide company form aimed primarily at supporting startups and scaleups, while being open to all founders and companies across the Union.
    IrelandCorporate/Commercial Law
    Matheson
    Matheson
  • Article

    Financial Transactions Tax, Feb 2013

    The European Commission unveiled its revised proposal for a new financial transaction tax (FTT) on 14 February 2013 following the decision by ECOFIN in January to proceed with the introduction of an FTT through "enhanced cooperation".
    IrelandTax
    Arthur Cox
    Arthur Cox
  • Article

    Revenue Information Powers: Lessons From Lifeplus V HMRC

    The Irish Revenue Commissioners are increasingly exercising their statutory powers to compel taxpayers to produce documents and information, both for domestic tax enquiries and in response to exchange of information requests from foreign tax administrations. A recent UK First-Tier Tribunal decision in Lifeplus Europe Ltd v HMRC provides valuable guidance on the scope and limits of these information-gathering powers, particularly regarding the concepts of 'reasonably required' and 'possession or power' in th
    IrelandTax
    Matheson
    Matheson
  • Article

    The Recast Directive On Administrative Cooperation – Key Proposed Changes To DAC6 Mandatory Disclosure Regime

    The European Commission's DAC Recast proposal introduces sweeping changes to cross-border tax reporting obligations, including a significant carve-out for multinational groups subject to Pillar Two's 15% minimum tax rate. With the removal of generic Category A hallmarks and extended reporting deadlines, the reforms promise over €1 billion in annual compliance savings while maintaining robust anti-avoidance protections. How will these targeted simplifications reshape the landscape of mandatory disclosu
    IrelandTax
    Arthur Cox
    Arthur Cox
  • Article

    Board Meetings And Company Residence: Change To Irish Revenue Practice From 1 January 2022

    Irish Revenue have recently confirmed their intention to withdraw an important concession which is relevant to directors' physical...
    IrelandCorporate/Commercial Law
    Arthur Cox
    Arthur Cox
  • Article

    Direct Tax Cases: Decisions From The Irish Courts And TAC Determinations

    The High Court in Farrell & Sons (Garages) Limited v Revenue Commissioners [2024] IEHC 553 considered whether a taxpayer could overturn two tax settlements that it had entered into with Revenue in 1995.
    IrelandTax
    RDJ LLP
    RDJ LLP
  • Article

    Irish Finance Bill 2021: Key Developments For Irish & International Business

    On 21 October 2021, the Irish Finance Bill 2021 (the "Bill") was published and contains over 220 pages of draft tax legislation.
    IrelandTax
    Maples Group
    Maples Group
  • Article

    Update on e-Stamping – Practical Filing Issues Since Introduction on 1 January 2010

    The e-stamping system went live on 1 January 2010. In a previous article, in the November 2009 edition of "Irish Tax Review", I examined the risk management aspects of the operation of the e-stamping system.
    IrelandTax
    LK Shields
    LK Shields
  • Article

    Side-by-side… Until It Isn’t: The Global Minimum Tax Under Strain

    The side-by-side package released by the OECD in early January was welcomed by the international tax community and heralded as demonstrating renewed commitment to international tax cooperation. While getting the agreement over the line was a triumph for international cooperation, that narrative misses what the side-by-side package means for international tax.
    IrelandTax
    Matheson
    Matheson
  • Article

    Irish Budget 2020 - A Roadmap For Irish And International Business

    The annual Irish Budget provides a platform for the Irish Minister for Finance to announce tax changes and also to take stock of Ireland's economy and strategy for future growth.
    IrelandTax
    Maples Group
    Maples Group
  • Article

    Irish Budget 2014

    On Tuesday 15 October 2013 the Irish Minister for Finance Michael Noonan presented Budget 2014, setting out the fiscal programme for the year ahead under which the Irish government plans to grow the Irish economy, create jobs and exit from the EU/IMF bailout programme.
    IrelandTax
    Maples Group
    Maples Group
  • Article

    Increased Publicity On MNE Taxes

    Large multinational enterprises face unprecedented public scrutiny as new EU transparency rules mandate the disclosure of country-by-country tax information for the first time. With the first wave of public reports set to be published in the coming months, how will MNEs navigate this new era of tax transparency and prepare for potential media attention around their global tax strategies?
    IrelandTax
    Matheson
    Matheson
  • Article

    Budget 2023 – Supporting Individuals, Families And Business

    The UK chancellor Kwasi Kwarteng's mini-budget sending the pound to a historical low (for a while at least) and increasing the cost of borrowing for the UK government by 100 basis points was certainly at the ...
    IrelandTax
    RDJ LLP
    RDJ LLP
  • Article

    Contractor Or Employee? Five Questions For Determining Employment Status

    The Supreme Court has issued its highly significant judgment in the matter of The Revenue Commissioners -V- Karshan Midlands Ltd TA Dominos Pizza.
    IrelandEmployment and HR
    RDJ LLP
    RDJ LLP
  • Article

    InDisputes – Land Development: When Is A Taxpayer Trading?

    In the recent case 196TACD2025, the Irish Tax Appeals Commission ("TAC") considered two interesting points; (i) whether a taxpayer was carrying on a trade of land development and entitled...
    IrelandTax
    Matheson
    Matheson
  • Showing 261–280 of 325 results

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