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Trade Cessation: Definition and Permanent Discontinuance
Clarifies when a trade is considered ceased and whether that cessation constitutes permanent discontinuance for tax purposes. Essential for traders determining cessation timing and permanent discontinuance status under TCA 1997 sections 67 and 382.
Corporation Tax Treatment of Public Private Partnership Projects
This document outlines corporation tax treatment for Public Private Partnership (PPP) projects including DBFOM, DBFO, DBO, and O&M models. It addresses whether unitary payments constitute trading income versus capital or rental income, and the tax treatment of leases in PPP arrangements. Necessary for consultants advising operators and awarding authorities on PPP taxation.
Management Expenses - Section 83 TCA 1997
This document summarizes the Supreme Court decision in Hibernian Insurance Company Ltd v MacUimis regarding whether certain disbursements constitute allowable management expenses. It clarifies that expenditure on evaluating potential business acquisitions and investment opportunities does not qualify as deductible management expenses, providing important precedent for corporation tax deductions. Relevant for companies claiming management expense deductions under section 83 TCA 1997.
Food and Accommodation Expenses - Trade Deductibility
Guidance on the tax deductibility of food and accommodation expenses under section 81 of the TCA 1997, explaining when such costs qualify as wholly and exclusively for trade purposes. Relevant for sole traders and business owners claiming meal and accommodation-related expenses.
Interest on Preference Share Redemption Loans
Supreme Court decision summary addressing the tax treatment of interest paid on loans used to redeem preference shares under section 81 of the TCA 1997. Applies to companies and individuals with corporate shareholdings engaging in preference share redemptions.
Case V Capital Allowances and Loss Set-Off Rules
Guidance on the order of set-off for Case V excess capital allowances and losses for individuals and jointly assessed spouses/civil partners under sections 97, 97A, 305, 381, 384, 406, 409A and 485C of the TCA 1997. Applies to landlords managing loss carryforward and allowance relief.
Rent-to-Buy and Similar Schemes
Guidance on the tax treatment of rent-to-buy schemes devised by builders and developers that allow prospective purchasers to live in a property during a trial period before purchase. Relevant for individuals considering property purchase arrangements and builders/developers offering incentive schemes.
Pillar Two Registration Guidance – TCA s.111A-111AAE
This document provides comprehensive guidance on registration requirements for multinational enterprise groups and large-scale domestic groups under Ireland's implementation of the OECD Pillar Two global minimum tax framework. It covers who must register, when to register, how to register, and obligations to maintain current registration details, including treatment of inactive, dormant, and dissolved entities. Essential for tax professionals advising groups subject to the 15% global minimum tax rate.
TCA Section 04A-10-01 - Income Tax, CGT & Corporation Tax
This document provides guidance on a specific aspect of Irish tax law covering income tax, capital gains tax, and corporation tax provisions. It is relevant to tax practitioners and consultants advising clients on TCA section 04A-10-01 matters. The document serves as a reference for understanding the tax treatment and compliance requirements under this provision.
Top-up Tax Information Return & DLE Notification – TCA Ch.10
A user guide for completing and filing Top-up Tax Information Returns (TIR) and Notification of Filer (NOF) forms under Ireland's Pillar Two implementation. This document outlines filing obligations, deadlines, the role of Designated Local Entities (DLE), and the legal framework governing TIR reporting in compliance with OECD Model Rules and Administrative Guidance. Relevant for groups with filing obligations under Chapter 10 of Part 4A of the TCA.
IIR, UTPR and QDTT Returns & Payments – TCA s.111A-111AAE
Detailed guidance on filing and payment obligations for Pillar Two returns including Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Top-up Tax (QDTT) returns. Covers group elections, filing deadlines, payment procedures, and the process for submitting Expressions of Doubt regarding tax positions. Essential for multinational groups determining which Pillar Two mechanisms apply and managing compliance obligations.