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Full coverage: Tax Appeals Commission

Project X and Company Y: How a major Irish tax row unveiled the rent-a-CEO structure at the core of multinational inversions

Through a series of mergers and demergers in the last decade, a global pharmaceutical manufacturer became Irish. To defend itself against a Vat claim, it had to reveal the details of the scheme.

Thomas Hubert
5th Jul, 2022 - 9 min read

Exit fees, success fees, and bonuses: When a corporate financier went to the Tax Appeals Commission

Are final payments described as “success fees” and “bonuses” taxable as annual income or eligible to lump sum relief? A four-year battle has just come to an end.

Thomas Hubert
8th Jun, 2022 - 5 min read

Revenue refunded a record amount of stamp duty last year. A pharma mega-merger explains it all

Exchequer returns showed swings of hundreds of millions of euros between 2020 and 2021 following a dispute on emergency stamp duty rules. The exact details of the settlement reached between AbbVie and the tax authority, however, remain secret.

Thomas Hubert
30th May, 2022 - 3 min read

Spousal transfers, share deals, and leveraged bonds: The €34.6m scheme that used the tax code to thwart the tax code

Described by Revenue as a “blatant misuse or abuse” of the tax code, a leveraged bond scheme gave rise to an inflated CGT loss of €34.6m for a husband and wife. But just how did it work? And why is the Revenue struggling to stop it?

I. Kehoe and E. O'Shea
19th May, 2022 - 6 min read

All multinationals in Ireland use intercompany debt – a €25m tax battle has just decided what happens when they unwind it

When the Irish treasury subsidiary of an overseas manufacturing group gained €200 million thanks to a loan waiver, the company declared this as non-taxable income. This led to a major test case.

Thomas Hubert
9th May, 2022 - 5 min read

Neymar, the IRFU and the Irish Open: How legal action by Listowel racecourse saved the sporting tax exemption

For the past decade, the Revenue Commissioners have pursued the Co Kerry horseracing organisation for corporation tax, arguing that betting and other ancillary activities were not sport. The case has now made its way through the High Court.

Thomas Hubert
4th May, 2022 - 6 min read

Counsellors, psychotherapists, and chiropractors avoid Vat bill. No such luck for Chinese medicine and acupuncture

To the relief of thousands of counsellors, psychotherapists and chiropractors, the authorities have said Vat need not be charged on their fees. However a practitioner of Chinese medicine and acupuncturist was not so lucky.

Eoin O'Shea
6th Apr, 2022 - 6 min read

How a €20 million gentleman’s agreement ended up on the wrong side of Revenue

On the basis of his word alone, a property investor tried to convince Revenue he was entitled to €750,000 in loss relief arising from a string of major property deals. It didn't go well.

Rosanna Cooney
7th Feb, 2022 - 5 min read

How four Irish high rollers took on Revenue over an elaborate scheme to reduce their tax bills – and won

Four significant media and entertainment investors used a complex Berlin bond tax scheme to essentially wipe massive sums off their tax bills. Now, in a major decision, the High Court has ruled in their favour.

Ian Kehoe
4th Feb, 2022 - 5 min read

Private practice? How Revenue tackled professionals transferring their business to a company

Many medical and other professionals have transferred their trade to a company. Now a doctor has been found personally liable for tax on fees earned through the new structure.

Eoin O'Shea
1st Feb, 2022 - 7 min read
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