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Articles by Caroline Devlin
EU Commission's Proposed New Tax Incentive For Equity Has A Sting In The Tail
On 11 May 2022, the European Commission published a new proposed directive to tackle the so-called debt-equity bias in taxation. The proposal includes both a new deductible equity allowance and a new interest restriction. What is the debt-equity bias? The debt-equity bias means that most tax regimes treat debt more favourably than equity by providing deductions from taxable income for interest payments on debt, but no similar deductions for equity.
Taxpayers Take Note: Important Changes In New Code Of Practice For Revenue Compliance Interventions
Intervention Levels The New Code includes three intervention “levels” for Revenue to deal with potential non-compliance by taxpayers. The New Code makes clear that these levels are not to be considered as a sequence of actions. This means that Revenue may initiate an intervention at any level of the framework without any prior intervention at a lower level, although an intervention at a lower level may lead to a higher level intervention.
Board Meetings And Company Residence: Expiry Of Irish Revenue Concession
Ireland: Board Meetings And Company Residence: Expiry Of Irish Revenue Concession 03 February 2022 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty , Orlaith Kane and Susan Lynch Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Board Meetings And Company Residence: Extension Of Concession To 31 January 2022
Ireland: Board Meetings And Company Residence: Extension Of Concession To 31 January 2022 12 January 2022 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty , Orlaith Kane and Susan Lynch Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Arthur Cox LLP Submission To Consultation On New Taxation Measures To Apply To Outbound Payments
Ireland: Arthur Cox LLP Submission To Consultation On New Taxation Measures To Apply To Outbound Payments 30 December 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty and Orlaith Kane Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Public Country By Country Reporting Update
European Union: Public Country By Country Reporting Update 24 December 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty , Orlaith Kane and Susan Lynch Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. The EU Directive on public country by country reporting of financial and tax information was published on 1 December 2021.
Board Meetings And Company Residence: Change To Irish Revenue Practice From 1 January 2022
To print this article, all you need is to be registered or login on Mondaq.com. Irish Revenue have recently confirmed their intention to withdraw an important concession which is relevant to directors' physical attendance at board meetings and company residence for Irish tax purposes.
Ireland's Consultation On OECD Tax Proposals
Ireland: Ireland's Consultation On OECD Tax Proposals 15 September 2021 by Fintan Clancy , Ailish Finnerty , Caroline Devlin , David Kilty and Susan Lynch Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. Arthur Cox last week made a submission to the Irish consultation on the OECD Tax Proposals.
Legal Flash – Redesigning The International Tax System: An Update - Tax - Ireland
Ireland: Legal Flash – Redesigning The International Tax System: An Update 22 June 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty and David Kilty Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. Significant changes to the international tax system are currently being negotiated.
Update On State Aid Claims And Tax Policy
European Union: Update On State Aid Claims And Tax Policy 21 June 2021 by Fintan Clancy , Ailish Finnerty , David Kilty and Caroline Devlin Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com. Following last year's landmark judgment in the Apple State aid case, the General Court of the European Union recently issued two important decisions in the area of State aid and tax policy.
EU Moves A Step Closer To Public Country-by-country Reporting Of Tax Information - Tax - European Union
European Union: EU Moves A Step Closer To Public Country-by-country Reporting Of Tax Information 09 June 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty and David Kilty Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Update: Court Of Appeal Sees Sense In Challenge To Validity Of Claim Notice
Ireland: Update: Court Of Appeal Sees Sense In Challenge To Validity Of Claim Notice 31 May 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty , Elaine Mooney and Suzanne Kearney Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Publication Of Details Of The New 10% Stamp Duty Rate For Bulk Buying Houses
Ireland: Publication Of Details Of The New 10% Stamp Duty Rate For Bulk Buying Houses 21 May 2021 by Fintan Clancy , Caroline Devlin , Ailish Finnerty , David Kilty and Kenneth Egan Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Repudiation Of Contracts / Leases Flying High After Irish High Court Decision In The Norwegian Air Shuttle ASA Examinership
Ireland: Repudiation Of Contracts / Leases Flying High After Irish High Court Decision In The Norwegian Air Shuttle ASA Examinership 29 April 2021 by William Day , John Donald , Kathleen Garrett , Caroline Devlin and Philippa Pierse Arthur Cox Your LinkedIn Connections with the authors To print this article, all you need is to be registered or login on Mondaq.com.
Transfer Pricing - Irish Revenue Publish New Transfer Pricing Guidance - Tax - Ireland
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Transfer Pricing - Irish Revenue publish new transfer pricing guidance | Lexology
Pursuant to Finance Act 2019, a number of changes were made to Ireland’s transfer pricing regime which are generally applicable for chargeable periods commencing on or after 1 January 2020 including: the extension of the transfer pricing rules to certain non-trading transactions, capital transactions where the market value of the relevant asset exceeds €25m and previously “grandfathered” transactions; the extension of transfer pricing rules to transactions involving SMEs, on the making of a...
Finance Bill 2020 - Finance and Banking - Ireland
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Budget 2021 - Tax - Ireland
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Buyer Beware - Sellers' Challenge To Validity Of Claim Notice Successful Despite Knowledge Of Ongoing Tax Investigation - Tax - Ireland
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Buyer Beware - Sellers’ challenge to validity of claim notice successful despite knowledge of ongoing tax investigation | Lexology
United Kingdom
September 28 2020 The High Court of England and Wales recently held that a claim under a tax covenant in a sale and purchase agreement was unenforceable because the claim notice did not contain sufficient detail of the matter which gave rise to the claim.
UK High Court Considers The Meaning Of
To print this article, all you need is to be registered or login on Mondaq.com. In AXA SA v Genworth Financial International Holdings, LLC [2020] EWHC 2024, the UK High Court had to determine the meaning of the term "subject to taxation in the hands of the receiving party" in the context of a gross-up clause in a share purchase agreement.
COVID-19: Employer Alert - Employment Wage Subsidy Scheme | Lexology
The Employment Wage Subsidy Scheme (“EWSS”) will operate from 1 September 2020 to 31 March 2021 and replaces the Temporary Wage Subsidy Scheme (“TWSS”) which will cease on 31 August 2020. Revenue published its EWSS Guidelines on 14 August 2020 in relation to the operation of the EWSS (available here) (the “Guidelines”).
Howzat! Cricketer Bowled Out For A Duck By HMRC In English High Court Tax Case
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Covid-19: Practical Considerations: Board Meetings & Corporate Tax Residence
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COVID-19 Temporary Wage Subsidy Scheme
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
COVID-19: Practical Considerations: Income Tax
Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice): Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below. Mondaq has a "free to view" business model.
COVID-19: Practical Considerations: Board Meetings & Corporate Tax Residence | Lexology
Due to the outbreak of COVID-19 and resulting restrictions on travel and meetings, it is necessary to find practical solutions to minimise disruptions to business, while ensuring compliance with public health recommendations regarding containment of the virus. This may include changes to arrangements in respect of company meetings which can affect corporate tax residence and impact on governance.
Fading competency of cytogenetic diagnostic laboratories: the alarm bell has started to ring
Clinical cytogenetics aims at the identification of chromosomal abnormalities by microscopic observation of metaphase chromosomes, known as karyotyping.
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