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Tax Issue - Summer 2020

Whilst Covid-19 has occupied the minds of most businesses for the last three months, the world of taxation does not stop. In this issue we provide an overview of the recent High Court case involving Perigo, which has raised some very interesting questions in relation to concepts of legitimate expectation in Irish tax law. The judgment in this case is eagerly awaited by tax practitioners. We also review a number of interesting recent determinations of the Tax Appeals Commissioners, one of which Revenue is appealing to the High Court which will make for very interesting reading as the Appeal Commissioner relied on EU VAT case law (which is generally binding in Ireland) in making their determination.

We also look at updated Revenue guidance notes in relation to short term business visitors undertaking employment duties in Ireland. Revenue have issued welcome clarification and have changed their previous approach, which was proving to be very confusing and was making the system unworkable. The new approach by Revenue is welcome. Finally we provide a summary of some international tax developments that Irish corporates need to be aware of including the changes in Ireland’s transfer pricing regime with effect from accounting periods beginning on or after 1 January 2020 and DAC 6 reporting obligations.

Please feel free to reach out to Ronan McGivern, Tax Partner, should you wish to discuss any of the attached in more detail.

Team Members

Ronan McGivern

Taxation Partner

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Mairead O'Grady

Taxation Partner

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Jackie Masterson

Taxation Partner

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Fiona Murphy

Taxation Partner

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Tax Issue - Summer 2020 137.61 KB

Whilst Covid-19 has occupied the minds of most businesses for the last three months, the world of taxation does not stop. In this issue we provide an overview of the recent High Court case involving Perigo, which has raised some very interesting questions in relation to concepts of legitimate expectative in Irish tax law. We also review a number of interesting recent determinations of the Tax Appeals Commissioners. We look at updated Revenue guidance notes in relation to short term business visitors undertaking employment duties in Ireland. Finally we provide a summary of some international tax developments that Irish corporates need to be aware of including the changes in Ireland’s transfer pricing regime with effect from accounting periods beginning on or after 1 January 2020 and DAC 6 reporting obligations.

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