BT Consulting - Inward Investment | Corporate Tax | Personal Tax | CGT | Estate Tax | Revenue Audits | BES & Patent Schemes

BT Consulting Publications
Relief for Capital Expenditure on Intangible Assets
Ireland has signed comprehensive double taxation agreements (“DTAs”) with 63 countries, of which 56 are in effect. A summary of these treaties and countries with whom treaty negotiations areongoing can be found here.
Irish Research and Development (“R&D”) tax credit regime
Companies that commence to carry on a new trade before 31 December 2014 are exempt from corporation tax and capital gains tax for the first three years provided that their tax liability in the year does not exceed €40,000. Therefore taxable profits in the sum of €320,000 per year or €960,000 over a three year period will be exempt from corporation tax.
The Irish Finance Act was enacted on 6th February 2011. One of the measures will have a significant impact on Irish interest free loan structures that are channelled via Luxembourg and The Netherlands. Following Finance Act 2011, interest relief to certain Irish companies with these lending structures will be reduced significantly in certain circumstances.
Prior to Finance Act 2011, betting duty of 1% only applied to bookmakers who are required to have a bookmaking license and who took bets in a betting shop. Betting duty will now be extended to bets taken by electronic means. Further, a new duty of 15% will apply to commissions earned by betting exchanges and a new licensing regime will be introduced for certain book makers and betting intermediaries.
The property boom is over, global recession is a reality; and the significant liquidity problems in the Irish banking sector will continue for a while. Many Irish businesses find themselves in unchartered waters and find themselves having to find new markets abroad. The tax issues associated with expanding abroad are considered.
Marie Bradley is the managing director of Bradley Tax Consulting, an international tax advisory firm based in Dublin. BTConsulting is a fully serviced international tax advisory firm and has particular expertise in the areas of Irish and international corporate acquisitions, reconstructions and reorganisations, foreign direct investment into Ireland and cross border tax planning for Irish companies expanding abroad. The firm deals with all direct and indirect taxes. “The firm has significant experience working with foreign advisors in other European jurisdictions, the US and around the globe, to assist multinational groups construct effective cross-border strategies and manage their global structural tax rate. Marie in this article focuses on Ireland as a place from which to undertake business operations.
Ireland has signed comprehensive double taxation agreements (“DTAs”) with 62 countries, of which 54 are in effect. A su mmary of these treaties and countries with whom treaty negotiations areongoing can be found here.
Finance Act 2010 introduced new transfer pricing provisions to be applied to trading transactions between associated persons. These provisions are intended to consolidate and expand on existing legislation in the Irish tax code and align Ireland with international standards by adopting the OECD arms length principles.
Since April 2008 an increasing number of multinationals have moved the tax residence of their corporate headquarters to Ireland. U.K. groups such as Shire Pharmaceuticals, Henderson, Charter, United Business Media and WPP are now headquartered in Ireland. Why Ireland?
The Irish Finance Bill was recently published. It contains a number of measures that increases Ireland’s attractiveness as a place in which to do business. A summary of the key measures that are of interest include....
Tax Considerations to be addressed
BT Consulting works with large companies to project manage the implementation of chosen tax strategies. In so doing it liaises with the client and their legal and accounting advisors to ensure that the relevant events to give effect to the strategy happen at the appropriate time.
Companies within the charge to Irish tax may now claim tax relief for capital expenditure incurred on acquiring intangible assets. The amortisation of intangible assets acquisition costs is another useful measure that the Irish tax system offers to encourage multi-national companies to locate and exploit intellectual property in Ireland.
How is Capital Acquisitions Tax (the term used to describe both gift tax and inheritance tax) calculated and when is it paid? What are the main CAT reliefs? Will I have to pay CAT if I buy a house with my partner and he/she predeceases me? What happens if I do not pay CAT or file a CAT return in respect of a gift of an investment property?
How is stamp duty calculated on the purchase of residential property? Who is a first time buyer for the purposes of the exemption from payment of stamp duty on the purchase of a residential property? Is there a stamp duty exemption for the transfer by a parent of a site to a child? What is the stamp duty payable on the sale or transfer of stocks and shares?
Finance Act 2006 contains most of the legislation governing the operation of the reliefs claimed by certain high earners. The treatment of tax reliefs carried forward by an individual and the resultant impact on the computation of taxable income is the focus of this article.
Capital Allowances and Property Incentives by Marie Bradley published by the Institute of Taxation