Background 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…
Read MoreAnticipating the assistance smaller businesses might require as they emerge from the financial challenges of pandemic, the Government has rightly come out with the Companies (Small Company Administrative Rescue Process and Miscellaneous Provisions) Bill 2021. What exactly Is the small company administrative rescue process and why is it needed? Small company administrative rescue process (also…
Read MoreIn simple terms, Enterprise Value (EV) is the total value of the company which includes its equity and debt. To arrive at this value, a pricing multiple is applied to the earnings before interest, tax, depreciation and amortisation (commonly referred to as EBITDA). However, from an M&A standpoint EV does not represent the ultimate value…
Read MoreEWSS Rates Following on from the Government’s announcement that the Employment Wage Subsidy Scheme (EWSS) would be extended until the end of December 2021, the below subsidy rates will continue to apply for the months of July, August and September 2021 based on employee’s gross pay per week: The subsidy rates payable for October 2021…
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