Taking a tax appeal
Navigating the tax appeal process in Ireland can seem daunting, but understanding the steps…
Entries by circulo
Revenue begin PRSA risk reviews
Finance Act 2022 amended the tax treatment of PRSA contributions by employers…
Elections and the close company surcharge
The Tax Appeals Commission recently ruled on an appeal (149TACD2024) concerning…
Minority discounting for share transfers
In an interesting decision (198TACD2024), the Tax Appeals Commission has ruled in favour of a taxpayer quashing an assessment to capital gains tax (CGT) in the amount €2,220,625. The case revolved around the gift of shares in a company and the application of a minority discount in the valuation of the shareholdings. Case Background The […]
Tax implications of share buybacks
Broadly, a company share buyback offers a mechanism whereby a shareholder can dispose of their shares in a company to the company itself for consideration, however, a company share buyback can generate unanticipated tax costs. Where a company buys back its shares for a price above the subscription price for the share any amount in […]
Business Asset Relief and Excess Cash
In this article, Mark Doyle and Gearalt O’Neill discuss the impact of cash balances on a claim for CAT Business Asset Relief.
Private company valuation for tax purposes in Ireland
Introduction The valuation of private companies for tax purposes holds significant importance within the Irish tax system. It plays a crucial role in accurately assessing the tax liability of shareholders in many different circumstances. Valuations undertaken for tax purposes must be guided by the relevant legislation for each tax head and often the valuation adopted […]
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Taking a tax appeal3 March 2025 - 14:47Navigating the tax appeal process in Ireland can seem daunting, but understanding the steps…
Minority discounting for share transfers13 February 2025 - 13:27In an interesting decision (198TACD2024), the Tax Appeals Commission has ruled in favour of a taxpayer quashing an assessment to capital gains tax (CGT) in the amount €2,220,625. The case revolved around the gift of shares in a company and the application of a minority discount in the valuation of the shareholdings. Case Background The […]
Tax implications of share buybacks4 January 2024 - 09:59Broadly, a company share buyback offers a mechanism whereby a shareholder can dispose of their shares in a company to the company itself for consideration, however, a company share buyback can generate unanticipated tax costs. Where a company buys back its shares for a price above the subscription price for the share any amount in […]
