As we start another year, we wanted to highlight some of the interesting tax consultancy projects we were involved with prior to the end of 2019.
Trust and Gift Tax Planning
Our Inheritance & Gift Tax team were involved in the complex reorganisation of a historical UK-based trust structure with Irish beneficiaries. The reorganisation was further complicated by the difference in tax treatment applied under UK and Irish trust tax law to different types of investments held by the trust, e.g. shares in companies, interests in property and offshore funds etc.
We ensured that the historical structure was reorganised, so that gifts could be made from the trust to the Irish beneficiaries, with minimal Irish or UK tax liabilities.
We also considered the Irish tax implications for a parent and an adult child on the immediate gift of a shareholding interest in a company, as well as the future gift of the remaining interest and minimised the tax impact by virtue of claiming entrepreneur relief, retirement relief and business asset relief.
Our Corporate Tax team:
We successfully settled two cases with the Tax Appeals Commission before the end of the year. This ended a lengthy process of negotiation on several tax technical matters.
We also liaised with Revenue in relation to ongoing Revenue Audits for clients across various tax heads including VAT, Income Tax and Capital Gains Tax. This involved liaising with and preparing technical written submissions to Revenue seeking to bring matters to a timely close for clients.
Engaging with Revenue on technical issues or taking a case to the Tax Appeals Commission can be a daunting process for many individuals, particularly those who do not have any prior experience in this area. If you would like to discuss this (or any of the above) further, please contact a member of our team.
During the year, we:
The area of pensions continues to be a hot topic with clients including some non-Irish tax resident clients choosing to migrate their retirement funds offshore and an increase in the number of Revenue interventions about self-administered pension schemes.
We advised a client on the sale of their shareholding in a company acquired by a UK company, to ensure that our client’s share disposal was not caught by anti-avoidance funding legislation, thereby enabling the event result in Capital Gains Tax treatment as opposed to Income Tax.
Please note: The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.
Warren & Partners are a boutique Irish tax and business advisory firm based in Ballsbridge, Dublin. Our experienced-team of tax advisors will create unique tax solutions for your specific business needs.