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The Mysterious World of Valuations (Irish Tax Review 2021 Issue 1)

Irish Tax Review Julie Burke Marie Flynn Sarah Kirwan
2021-04-19
...is that they can be subjective and can also change frequently, depending on both external environmental factors and internal factors based on the asset itself. The year 2020 was a particularly challenging one on the valuation purposes, given the level of uncertainty caused by the Covid-19 pandemic and Brexit, the buoyant recovery and continued growth of the stock markets, the high level of transactional activity, and the disparity caused by unprecedented growth in certain sectors and unprecedented decline in others. 2021 has started in a similar vein, but with hope on the horizon in terms of...
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Irish Tax Review Julie Burke Anne Gunnell
2020-09-22
...changes for consideration in drafting Finance Bill 2020. The submission covered various legislative technical amendments, identified in conjunction with our Policy & Technical Committee, needed to enhance existing tax incentives for SMEs, including KEEP and EII; measures to provide tax certainty for domestic and international businesses, including Brexit-related tax measures; and measures to support business succession.

Relationship Breakdown: Tax Implications (Irish Tax Review 2020 Issue 4)

Irish Tax Review Julie Burke Amanda-Jayne Comyn
2020-12-14
The Family Law Act 2019 also provided for the recognition of all foreign divorces granted in the European Union (to include Britain and Gibraltar after Brexit). Previously, foreign divorces were valid in Ireland only if they were recognised here under the Domicile and Recognition of Foreign Divorces Act 1986. An application to court can be made to have a foreign marriage or divorce recognised in Ireland.

Legislation & Policy Monitor (Irish Tax Review 2020 Issue 4)

Irish Tax Review Julie Burke Lorraine Sheegar
2020-12-14
Brexit: Commission sends letter of formal notice to the UK for breaching its obligations under the Withdrawal Agreement
Irish Tax Review Julie Burke Kathryn Brady Aoife Reilly
2020-03-23
...-border commuters, short-term assignees and ad hoc business trippers. Business travellers include those who travel from parent companies based in the United States and the United Kingdom to Ireland for meetings, for short projects or to provide experience and guidance to Irish staff. In the context of Brexit, for example, it includes senior executives flying from London to Dublin for three or four days a month to assist with the establishment of new Irish operations. In many circumstances the fact that these individuals are spending time working in Ireland may trigger Irish tax withholding obligations, as... … In contrast, EU and EEA nationals do not require permission to take up employment in Ireland or for business travel to Ireland. Although Brexit remains a contentious topic, the preservation of the Common Travel Area between Ireland and the United Kingdom has offered a certain level of comfort to employers and employees regarding business travel between Ireland and the United Kingdom.
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UK 2018 Budget: Summary of Announcements (Irish Tax Review 2019 Issue 1)

Irish Tax Review Julie Burke Roger Campbell Mathew Scott
2019-04-01
...being an early adopter of measures to combat base erosion and profit shifting (BEPS). This raises the question of what policies can be introduced not only to attract foreign business but also to retain businesses that already have a significant footprint in the UK – especially in these turbulent Brexit times. … ...inhibit inbound investment, partly due to potential restrictions on the freedom of movement of workers, although the new immigration rules are not yet finalised. In particular, economic growth and inbound investment outside of London may be impacted by the minimum income requirements (£30K) in the proposed post-Brexit immigration system. This requirement may make it more difficult for employers to recruit employees and therefore constrain any expansion plans and inbound investment. … ...announcements should help to spur capital investment by both UK companies and overseas businesses seeking to expand operations. The reform of the intangible degrouping charge will also serve to reduce the barriers and complexities to successful M&A transactions. However, these changes have to be balanced against the general Brexit environment, which is having a much more significant impact on M&A activity. … ...reducing to 17% from 1 April 2020), significant reliefs available for R&D/qualifying patent box expenditure and an attractive dividend/withholding tax exemption – show that the UK is open for business. At the time you are reading this there may even be some clarity over what Brexit means (at least for the transitional period). If so, the impact of the tax measures introduced may have more significance.
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Irish Tax Review Julie Burke Patrick Harney Nicola Simmons
2020-09-22
Brexit notwithstanding, the UK remains a stable investment environment and is likely to continue to be popular for Irish investors. The free base-cost uplifts of April 2015 and 2019 for UK residential and commercial property, respectively, represent potential planning opportunities for Irish taxpayers who are long-term holders...
Irish Tax Review Julie Burke Clare Wardell Ian Collins
2020-09-22
...kilter with the other measures that Revenue introduced to encourage and incentivise small and micro companies to engage with the R&D tax credit regime. Given the uncharted times we face with the Covid-19 pandemic, as well as significant political uncertainty around the globe (not to mention that Brexit is back on the agenda), it is the authors’ view that we cannot be complacent about the attractiveness and competitiveness of our R&D regime and Ireland’s ability to attract investment from both indigenous companies and FDI businesses. In the authors’ view continuing to squeeze the...
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Corporate Debt Restructuring (Irish Tax Review 2020 Issue 3)

Irish Tax Review Julie Burke Colm O’Callaghan Danielle Grant
2020-09-22
The Covid-19 pandemic, combined with the looming prospect of a hard Brexit, have led to unprecedented levels of uncertainty for most, if not all, Irish businesses. From the shorter-term impact felt on cash-flow (due to the recent lockdown) to the longer-term impact of a likely reduction in demand due to an almost inevitable global recession,...
Irish Tax Review Julie Burke Kevin Ryan Ally McCaffrey Colin Smith (not pictured)
2020-03-23
It is worth noting that although legislation extending the updated transfer pricing rules to SMEs has been included in the Finance Act, the commencement of this extension will be subject to a Ministerial Order. Given the uncertainty that Brexit is bringing to the SME sector, it was decided that it is not appropriate to introduce the rules at this time. The Department of Finance has noted that the execution of a Ministerial Order will be signalled in advance. If introduced, tailored transfer pricing documentation requirements for SMEs...
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