Taxation Of Company Reorganisations In Ireland

Author : Evelyn Ford
Publisher : A&C Black
Page : 477 pages
File Size : 49,5 Mb
Release : 2011-08-31
Category : Law
ISBN : 9781847663771

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Taxation of Company Reorganisations in Ireland by Evelyn Ford Pdf

This unique new title is the only Irish tax publication which provides an in-depth and comprehensive analysis of the Irish tax issues arising in company reorganisations and reconstructions. The book adopts a practical approach to examining the principal considerations arising from the types of reorganisations typically undertaken by Irish companies. The text includes a number of worked examples, case studies and tax planning points relevant to this complex area. Providing a comprehensive analysis of relevance to tax practitioners in both large and small tax firms, it considers the practical application of tax law in key areas, including:- Restructurings in the context of incorporation - Group reorganisations/reconstructions - Restructurings for sale - Share capital reorganisations - Earn outs and long term incentive schemes - Anti-avoidance - An introduction to relevant company law and accounting issues is also included. EURO: 175

Author : Pete Miller,George Hardy,Fehzaan Ismail
Publisher : Bloomsbury Professional
Page : 0 pages
File Size : 54,7 Mb
Release : 2020-11-11
Category : Business & Economics
ISBN : 1526511495

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Taxation of Company Reorganisations by Pete Miller,George Hardy,Fehzaan Ismail Pdf

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)

Author : PETE. HARDY MILLER (GEORGE.),George Hardy (Ph. D.)
Publisher : Unknown
Page : 672 pages
File Size : 47,5 Mb
Release : 2019
Category : Corporate reorganizations
ISBN : 1526511525

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Taxation of Company Reorganisations by PETE. HARDY MILLER (GEORGE.),George Hardy (Ph. D.) Pdf

Author : Pete Miller,George Hardy,Fehzaan Ismail
Publisher : Bloomsbury Publishing
Page : 749 pages
File Size : 42,5 Mb
Release : 2020-10-05
Category : Business & Economics
ISBN : 9781526511515

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Taxation of Company Reorganisations by Pete Miller,George Hardy,Fehzaan Ismail Pdf

Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)

Author : Jérôme Vermeylen,Ivo Vande Velde
Publisher : OUP Oxford
Page : 1587 pages
File Size : 48,9 Mb
Release : 2012-03-29
Category : Law
ISBN : 9780191630996

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European Cross-Border Mergers and Reorganisations by Jérôme Vermeylen,Ivo Vande Velde Pdf

The most comprehensive guide to all techniques available to European companies, European Cross-Border Mergers and Reorganisations is the ideal reference tool for lawyers, auditors, notaries and scholars working in the field. Providing everything a practitioner needs to co-ordinate a successful cross-border merger, the book analyses the EU Directives and how they have been applied in each of the main EU/EEA member states. The diverging rules for each jurisdiction are highlighted and explained enabling quick comparisons to be made between countries for assessing feasibility of the chosen technique. As well as the requirements, formalities and potential pitfalls of cross-border mergers, each country analysis addresses the relevant aspects of corporate, employment and tax law such as informing shareholders and employees, verification of the legality of the merger, and language requirements. The book also considers other cross-border reorganisation techniques, such as demergers, partial demergers, the transfer of branches of activity, the creation of a Societas Europaea, or a Societas Cooperativa Europea, and the cross-boarder transfer of a company's head office or registered office, providing a practical guide to the best possible solution for a practitioner's client. European Cross-Border Reorganisations: Law and Practice is an easy-to-use reference work for legal, tax and audit professionals involved in mergers.

Author : Michael Feeney
Publisher : Bloomsbury Publishing
Page : 2416 pages
File Size : 44,6 Mb
Release : 2019-04-19
Category : Law
ISBN : 9781526506924

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Feeney: The Taxation of Companies 2019 by Michael Feeney Pdf

This key book provides the most comprehensive analysis and commentary available on the taxation of companies in Ireland. Now in its 23rd year of publication, this extremely practical book features detailed worked examples and extensive references to case law throughout the work. The guidance and advice outlines how to successfully apply the new tax reliefs, keeping your clients' tax liabilities as low as possible. This new edition has been updated to the Finance Act 2018 and incorporates the many substantive legal changes that have taken place in the last year, including: - The new controlled foreign companies legislation: whereby, for Irish tax purposes, undistributed income of controlled foreign subsidiaries may be attributed to an Irish controlling company of those subsidiaries. - The capital gains tax exit charge legislation, which has been completely re-written and substituted for the existing legislation. - Film relief, which has been extended for another four years, to 31 December 2024, but which has also been extensively amended There have also been numerous legal smaller changes that have been addressed and incorporated into this new edition, such as the technical change in specified tangible assets to the 80% restriction on allowable capital allowances, the extension of accelerated capital allowances to expenditure on energy-efficient equipment, the accelerated capital allowances for equipment and buildings for childcare centres or fitness centres for employee and the extension of relief for start-up companies.

Author : Carsten Wendt
Publisher : Springer Science & Business Media
Page : 231 pages
File Size : 45,8 Mb
Release : 2009-04-16
Category : Business & Economics
ISBN : 9783834981936

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A Common Tax Base for Multinational Enterprises in the European Union by Carsten Wendt Pdf

Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.

Author : Dennis Campbell
Publisher : Lulu.com
Page : 394 pages
File Size : 45,8 Mb
Release : 2009-08-12
Category : Law
ISBN : 9780557091256

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International Taxation of Low-Tax Transactions [2009] - Low-Tax Jurisdictions I by Dennis Campbell Pdf

2009 RELEASE: "International Taxation of Low-Tax Transactions, Low-Tax Jurisdictions, Volume I" - A three-volume set with nearly 1,200 pages, offers tax specialists from North and South America, Europe, Asia and the Pacific, and the Middle East who examine the treatment by high-tax countries of transactions originating from and holdings based in low-tax jurisdictions, providing an essential tool for practitioners dealing with the crossborder movement of capital and other assets. The publication is replaced by updated volumes annually. Order Low-Tax Jurisdictions, Volume 2, and High-Tax Jurisdictions, to complete the set. A 25% discount applies to a subscription for three years of updates. Discounts are applied after purchase by rebate from publisher.

Author : Anonim
Publisher : Unknown
Page : 428 pages
File Size : 40,6 Mb
Release : 1999
Category : Electronic
ISBN : UIUC:30112047472706

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The Tax Management International Forum by Anonim Pdf

Author : Nicola Saccardo
Publisher : Bloomsbury Publishing
Page : 553 pages
File Size : 49,8 Mb
Release : 2021-05-21
Category : Business & Economics
ISBN : 9781526516824

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Tax Implications of Brexit by Nicola Saccardo Pdf

Tax Implications of Brexit is an essential guide for anyone advising businesses trading in either the United Kingdom or the European Union post-Brexit. In two parts, this title provides an in-depth analysis of the tax ramifications of Brexit in both the United Kingdom and EU Member States, helping to identify immediate and future issues that could be faced post-Brexit, and how to mitigate any risks. Part One features subject-specific chapters which deal with the UK statutory regime after 2020 as well as the impact of Brexit on VAT, customs and excise duties and State Aid legislation. Part Two is split into country chapters dealing with the tax implications in the single jurisdictions (the United Kingdom and EU Member States) for cross-border investments between the United Kingdom and the EU and for UK-EU cross-border reorganisations. This book is essential reading for tax professionals advising businesses trading in the United Kingdom or in the European Union, but also tax managers of those businesses. Tax Implications of Brexit includes contributions from Barbara Belgrano, Conor Quigley QC, Julian Ghosh QC, Kelly Stricklin-Coutinho, Nicola Saccardo, Roderick Cordara QC, Timothy Lyons QC and a plethora of highly respected tax experts from EU jurisdictions.

Author : OECD
Publisher : OECD Publishing
Page : 88 pages
File Size : 43,5 Mb
Release : 2010-09-15
Category : Electronic
ISBN : 9789264088689

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Addressing Tax Risks Involving Bank Losses by OECD Pdf

This book provides an overview of the tax treatment of banks’ tax losses losses in 17 OECD countries; describes the tax risks that arise in relation to these losses; outlines the incentives that give rise to these risks, and describes how these risks can be reduced.

Author : Dieter Endres,PricewaterhouseCoopers LLP.
Publisher : Kluwer Law International B.V.
Page : 850 pages
File Size : 50,5 Mb
Release : 2007-01-01
Category : Law
ISBN : 9789041125507

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The Determination of Corporate Taxable Income in the EU Member States by Dieter Endres,PricewaterhouseCoopers LLP. Pdf

This book discusses whether elements of the international financial reporting standards (IFRS) meet the requirements of potential common European tax accounting rules. The analysis is based on general principles of taxation and on a comprehensive comparative survey of selected IFRS and tax accounting rules for all 25 EU member states (conducted by the universities of Goettingen, Mannheim, and Erlangen-Nuremberg with the support of PricewaterhouseCoopers). It concludes that, in principle, there is no irresolvable conflict between IFRS and the current tax accounting rules in the member states. After an introduction the book considers the general principles of taxation, followed by a comparative survey of IFRS and tax accounting rules in the EU member states, including taxation of corporations, determination of income, recognition, initial measurement, subsequent measurement, and special areas: pensions, leasing, treatment of domestic and foreign losses, and group taxation. Then follows an analysis of common and fundamental accounting principles, including conceptual accounting principles, accrual principles, treatment of losses, and definition of a group and consolidation. The appendices show how each country computes taxable income and grants tax incentives.

Author : Tom Maguire
Publisher : Bloomsbury Publishing
Page : 2870 pages
File Size : 45,7 Mb
Release : 2021-09-30
Category : Law
ISBN : 9781526520012

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Irish Income Tax 2021 by Tom Maguire Pdf

'The Bible of Irish income tax...' - Irish Independent, 28 January 2018 Tom Maguire's annual publication on Irish income tax is the long-established leading authority in the area. This immensely popular tax essential is the number one income tax book for tax practitioners, accountants and tax lawyers. Indispensable in practice, it will help you to apply the relevant legislation with ease and precision. It endeavours to provide a complete analysis of the principles and practice of income tax in the Republic of Ireland. This new edition is based on the Finance Act 2020. It also provides an examination of recent key decisions by the courts both here and in the UK, as well as by the Tax Appeal Commissioners. The 2021 edition deals with changes in relation to pandemic unemployment payments, the dependent relative tax credit and the mobility allowance. In particular the new edition examines the impact of the Covid Restrictions Support Scheme, which is available to eligible businesses who carry on an activity that is impacted by the Covid-19 Restrictions.

Author : Niklas Schmidt,Jack Bernstein,Stefan Richter,Lisa Zarlenga
Publisher : Kluwer Law International B.V.
Page : 677 pages
File Size : 50,5 Mb
Release : 2020-11-27
Category : Law
ISBN : 9789403523514

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Taxation of Crypto Assets by Niklas Schmidt,Jack Bernstein,Stefan Richter,Lisa Zarlenga Pdf

The emergence of crypto assets has required taxation authorities worldwide to develop unprecedented policies and compelled tax lawyers to apply existing laws in new ways. This book – the only one to focus solely on the taxation of crypto assets – provides a detailed country-by-country analysis of how the tax law of thirty-nine countries may apply to this rapidly developing area, including different use cases and compliance and documentation requirements. Following an overview of the technology and key characteristics of crypto assets, as well as the key tax concepts and types of taxes that could apply to them, leading practitioners in each particular jurisdiction summarize the relevant tax law in that country. Fully explained are such aspects of crypto assets as the following and how they are interrelated: sales; exchanges; receipt as remuneration; forks; airdrops; mining; staking; initial coin offerings; security token offerings; and initial exchange offerings. Contributors describe how each jurisdiction applies income and capital gains taxation, value-added tax and sales tax, withholding taxes, transfer taxes, and gift, inheritance, estate and wealth taxes in the context of crypto assets. Reporting requirements and enforcement are also covered. Tax law, as it applies to crypto assets, is new and continues to evolve. This book will be welcomed as the premier resource for tax practitioners, government officials, advisors, investors, issuers, users of crypto assets, and taxation academics who are seeking informed awareness of the policy choices countries make in dealing with the taxation of this new technology. Tax lawyers dealing with crypto assets will have comprehensive practical guidance on how to comply with the tax laws of multiple jurisdictions.

Author : Amanda D. Johnson
Publisher : WorldTrade Executive, Inc.
Page : 170 pages
File Size : 45,8 Mb
Release : 2005
Category : Business & Economics
ISBN : 1893323706

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Using Treaties and Holding Companies for Latin American Tax Planning by Amanda D. Johnson Pdf

Collection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.