Background In order to discourage the purchase of multiple residential units by any one individual or entity in the context of the current housing crisis and the ongoing shortage of housing for owner-occupier purchasers, a higher rate of stamp duty was introduced on the acquisition of certain residential property. Section 31E SDCA 1999 charges a…
Read MoreHighlights for you and your business Budget 2022 was announced by the Minister for Finance and the Minister for Public Expenditure and Reform yesterday afternoon. The focus of this year’s budget is to balance the need for continued supports for businesses as we emerge from the pandemic and also to continue to restore public services,…
Read MoreThe recent introduction of EU (Anti-Money Laundering: Beneficial Ownership of Trusts) Regulations 2021 imposes new obligations on trustees of relevant trusts. The purpose of the Central Register of Beneficial Ownership of Trusts is to improve transparency on who ultimately owns and controls Irish trusts and to help prevent money laundering and terrorist financing. In addition…
Read MoreBackground The Irish Revenue have always been ahead of the curve with the use of information technology and data processing. When you combine this with the vast amount of information the Revenue receives and their ability to analyse and link the same with taxpayers. Revenue Information Sources Revenue has numerous sources of information. The main…
Read MoreBackground The European Commission has requested that Ireland transpose into Irish law the interest limitation rule (ILR) as required by the EU’s Anti-Tax Avoidance Directive (ATAD). Ireland contended that its current interest limitation rules are “equally effective” and notified derogation requests under EU law, which has not been granted by the European Commission. Interest Limitation…
Read MoreRevenue eBrief 120/21 was issued on 20 June 2021. It deals with two aspects as follows: The new share schemes reporting return (Form ESA), and Notification that two new chapters have been added to the Shares Schemes manual. FORM ESA Finance Act 2020 provides for the mandatory electronic reporting of certain share-based remuneration. This includes…
Read MoreBackground On 4 June 2021, the Revenue issued updated guidance on the warehousing of tax debts, which both simplified and clarified the position. The Revenue Information Booklet is available at – https://www.revenue.ie/en/corporate/communications/documents/debt-warehousing-reduced-interest-measures.pdf Tax Debt that can be warehoused VAT, Employers PAYE, Income Tax and TWSS/EWSS in relation to taxpayers dealt with by the Revenues Business…
Read MoreRevenue has issued a guidance note on Growth shares dated July 2021. This note is of relevance in terms of providing equity participation to key management. What is a Growth Share? Revenue describes growth shares as: “ a special class of ordinary shares that generally have a low or nil value until a certain target…
Read MoreIreland’s 12.5% Corporation Tax Regime Background Since 2017, efforts have been made by 139 countries to jointly develop a “two-pillar” framework to address tax challenges arising from the digitalisation of the world economy. The purpose of this paper is to give a general overview of what are very complex proposals. Pillar One The scope of…
Read MoreA contentious issue in M&A deals can often be the working capital adjustment that is embedded in the SPA. Albeit the term normalised working capital (NWC) may be familiar to many, its nuances are often misunderstood in the context of a purchase price adjustment as a part of the acquisition. This article discusses the fundamentals…
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