The High Court has overruled a determination of the Tax Appeals Commission that the multinational technology company was not liable for $4.9m in royalty withholding taxes incurred abroad.
The Government is facing industry opposition, intense lobbying, and backbencher resistance over proposals aimed at airing tax appeals in public – but Simon Harris says he is constrained by a Supreme Court decision.
Aoife Quinn is in a tax dispute with Revenue over monies drawn down from “bogus” employment contracts with three Russian companies in 2011 and 2012. The daughter of former billionaire Sean Quinn says the money was used in the family’s court battle with IBRC.
Revenue's notice of appeal in the Getty case was described by the Tax Appeal Commission as “vague, unnecessarily repetitious, and/or not reflective of a point of law capable of forming a question for the High Court”.
Between 2015 and 2018 Getty claimed over €31.4m in foreign royalty withholding tax as a deductible expense in its Irish corporation tax returns. Revenue is fighting an uphill battle to block the move.
A €2.2m dispute between a company founder and the Revenue Commissioners has shed light on how minority discounts apply to share-based transactions.
The Revenue Commissioners have won 39 cases in relation to the scheme before the Tax Appeals Commission. The result is a major victory for the authority, which began raising assessments in relation to the scheme in recent years.
Between 2010 and 2012, international trader Susquehanna tried to claim tax relief on group losses. In the face of Revenue opposition, it won its case — and then lost it.
A tax scheme involving employee benefit trusts is one of 35 transactions under active investigation by Revenue. A test case has now determined that the scheme falls outside tax law, a decision that has implications for dozens of high rollers.
A battle between a businessman and the tax authority has clarified case law on convertible loans and CGT losses.
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