The Courts and the Tax Appeals Commission have considered the following issues in recent months, including:
- Can a taxpayer overturn their own tax settlement?
- Close company surcharge – what is the time-limit to make the joint-election?
- Payments to directors – loan or emolument – whether Companies Act provisions relevant to tax treatment?
- How do fiscally transparent entities (such as US LLCs) interact with DTA provisions?
Senior Associate Mark Ludlow is a regular contributor to the Irish Tax Review, writing the feature Direct Tax Cases: Decisions from the Irish Courts and Tax Appeals Commission Determinations. The current feature examines decisions which considered the above questions and others.
Read the full article here.
This article first appeared in Irish Tax Review Issue 4
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