Entries by circulo

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 […]

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 […]