CPDStore Ireland

26th Nov, 09:00

Tax Implications of Business Decisions

Speaker: Conor Kennedy – EY Law Ireland

There are over 60 specific provisions in the Tax Acts to challenge a ‘primarily tax motivated, non bona fide commercial transaction’. The omnipresent threat of the general anti-avoidance provision, TCA, section 811C, also lurks in the undergrowth to catch any other perceived abuse of the tax system. Other provisions such as TCA, sections 806 and 817 could apply where there has been any tax motivation.

The specific anti-avoidance measures cover transactions such as retirements, company reconstructions, amalgamations, share disposals, company groups, transfer pricing, interest deductions, company share buybacks and an assortment of investment opportunities. These provisions entitle Revenue to modify or deny the tax benefits.

Although the Irish Courts have considered the general anti-avoidance provision, there has been no corresponding deliberations on the meaning of the concept of a ‘primarily tax motivated non bona fide commercial transaction’. However, there have been some recent Court of Appeal decisions in England and Wales that have provided judicial clarification. Though not binding, such authorities are persuasive in this jurisdiction specifically where similar statutory wording is under consideration.

While there is no widespread paranoia, there are concerns among practitioners of the possibility that Revenue may challenge any transaction benefiting from a tax allowance, relief, or deduction. The seminar considers the Court of Appeal decisions and the steps that practitioners should take to satisfy Revenue of the commercial legitimacy of any impugned transactions where tax avoidance is not the primary motivation.

Conor Kennedy will cover the following topics during this webinar:>br>
• A review of the assortment of specific tax avoidance provisions
• Case law that considers non contentious tax planning
• Legal analysis
• Type of transactions that would not be primarily tax motivated
• Steps to be followed when advising clients

By attending this session, you will be able to appreciate the risks in providing tax advice and the necessary steps to be taken to minimise risk of Revenue challenges to the tax integrity of a transaction.

This session will be of particular interest to tax advisers, auditors, business owners.

Course Level: Intermediate

26th Nov, 11:00

Tax Reliefs for the Corporate Office

Speaker: Paul Murphy – Martin J Kelly & Co
This session is designed to equip the attendee with an overview of the main reliefs available in the corporate environment for the industry accountant.

Paul Murphy will cover the following topics during this webinar:

• Corporation tax reliefs – including R&D & start-up
• Group relief overview
• Employment terminations
• Pension funding
• Shareholder exits

By attending this session, you will be familiar with the current reliefs available for companies in a variety of situations including restructurings, terminations and groups.

This session will be of particular interest to accountants in industry who would like to have a general knowledge of the main reliefs available to companies.

Course Level: Intermediate

26th Nov, 13:40

Corporate Reporting 2024

Speaker: Lindsay Webber – OmniPro Practice Support

Course details will be available closer to the event date.

26th Nov, 15:40

Employed or Self-Employed – That is the Question

Speaker: Barry Crushell – Crushell & Co

Course details will be available closer to the event date.