Interpretation of s291A involving expenditure on the acquisition of fishing capacity as an specified intangible asset
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Appeal regarding the business of power generation and whether connection fees should be relievable as ancillary expenditure on the provision of plant and machinery or whether the expenditure should be treated as revenue expenditure and therefore be deemed deductible, s396 TCA 1997. The determination also considered the question of legitimate expectation and the four-year limitation period
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Appeal whether the business of the Appellant consists of or includes the carrying on of a profession or the provision of professional services within the charge to tax, s441 TCA 1997
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Appeal regarding refusal for sporting tax exemption s235 TCA 1997
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Appeal relating to surcharge imposed for the late filing of financial statements via iXBRL
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Appeal regarding surcharge on undistributed income of service companies s441 TCA97
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Appeal regarding s21, s26 TCA 1997, interpreted in accordance with s96(3) TCA 1997 on charge to corporation tax in respect of rental income
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Entitlement to group relief under s411 TCA97 and Article 25.4 of the Convention between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains
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Whether the tax withheld on foreign dividends is a deductible expense for the purposes of calculating profits assessable to corporation tax in accordance with s81 TCA1997
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Whether foreign withholding tax incurred by the Appellant comprises monies ‘laid out or expended for the purposes of the trade’ in accordance with s81(2)(a) TCA 1997, or whether such monies may be treated as a loss in accordance with s81(2)(e) TCA 1997
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