Share for share exchanges and the application of specific anti-avoidance legislation The Tax Appeal Commission (“TAC”) has given a determination in a case involving share for share exchange relief (case 58TACD2025). The Appellant claimed relief from CGT on a share for share exchange under section 586 of the Taxes Consolidation Act 1997 (“TCA 1997”). […]
When is the date of disposal of an asset for CGT purposes? The recent Court of Appeal decision in Sean Flaherty v. The Revenue Commissioners has significant implications for tax advisors, particularly regarding the interpretation of the “date of disposal” for Capital Gains Tax (CGT) purposes. This case highlights the importance of understanding contract conditions […]
Navigating the tax appeal process in Ireland can seem daunting, but understanding the steps…
Finance Act 2022 amended the tax treatment of PRSA contributions by employers…
The Tax Appeals Commission recently ruled on an appeal (149TACD2024) concerning…
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 […]
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 […]
In this article, Mark Doyle and Gearalt O’Neill discuss the impact of cash balances on a claim for CAT Business Asset Relief.
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 […]
Share for share exchanges and the application of specific anti-avoidance legislation13 July 2025 - 07:37Share for share exchanges and the application of specific anti-avoidance legislation The Tax Appeal Commission (“TAC”) has given a determination in a case involving share for share exchange relief (case 58TACD2025). The Appellant claimed relief from CGT on a share for share exchange under section 586 of the Taxes Consolidation Act 1997 (“TCA 1997”). […]
When is the date of disposal of an asset for CGT purposes?30 April 2025 - 14:10When is the date of disposal of an asset for CGT purposes? The recent Court of Appeal decision in Sean Flaherty v. The Revenue Commissioners has significant implications for tax advisors, particularly regarding the interpretation of the “date of disposal” for Capital Gains Tax (CGT) purposes. This case highlights the importance of understanding contract conditions […]
Taking a tax appeal3 March 2025 - 14:47Navigating the tax appeal process in Ireland can seem daunting, but understanding the steps…
