Overview of corporate tax work over the last year
Financial services
Mergers and acquisitions
2019 was another strong year for M&A activity in
Aircraft leasing and aviation finance
Intellectual property
Tax disputes
2019 was a significant year for
Of particular note are the developments in the Perrigo tax case over the past year. This case arose out of a €1.64 billion assessment issued by the Irish Revenue Commissioners ("Revenue") in 2018 against
Key developments affecting corporate tax law and practice
COVID-19 pandemic response
At the time of writing, Revenue has issued guidance on many tax issues arising from the COVID-19 pandemic and the restrictions introduced to reduce the spread of the disease. Among the measures introduced by Revenue are the following:
- The suspension of the application of a surcharge for late corporation tax return filings for accounting periods ending
June 2019 onwards. The late filing will also not trigger any restriction of reliefs, such as loss relief and group relief, as would ordinarily be required. - The suspension of Revenue's debt collection and accrual of interest on late payments for the January-June Value-Added Tax ("VAT") periods and February-June pay-asyou-earn ("PAYE") (Employer) liabilities 2020.
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The filing deadline for all 2019 share scheme returns has been extended from
31 March 2020 to30 June 2020 . - The 90-day employer filing obligation applicable to the Special Assignee Relief Programme ("SARP") has been extended for a further 60 days.
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Cross-border workers relief will not be affected by employees being required to work from home in
Ireland due to COVID-19. Similarly, Revenue will not enforce Irish payroll obligations where an employee relocates temporarily toIreland during the COVID-19 period and performs duties for their employer fromIreland . - Revenue will not strictly enforce the 30-day notification requirement for PAYE dispensations applicable to certain short-term business travellers.
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PAYE exclusion orders will not be adversely affected by an employee working more than 30 days in
Ireland as a result of COVID-19. -
For the purposes of Irish tax residency rules, where a departure from
Ireland is prevented due to COVID-19, Revenue will consider this force majeure for the purpose of establishing an individual's tax residence position. -
For the purposes of corporate tax residence, Revenue will disregard presence of employees, directors, service providers or agents in
Ireland or outsideIreland resulting from COVID-19-related travel restrictions. In these circumstances, Revenue has advised that the individual and company should maintain a record of the facts of the bona fide relevant presence in or outsideIreland . -
Following the adoption of Council Directive (EU) 2020/876 which allowed for the deferral of the exchange dates for DAC2, and the filing and exchange dates for DAC6, Revenue has confirmed that the deadline for filing DAC2 returns in respect of the 2019 reporting period is now deferred until
30 September 2020 . This deadline will also apply for the filing of Common Reporting Standard and Foreign Account Tax Compliance Act returns. Finally, DAC6 reporting deadlines have been deferred by six months. -
Importation of goods to combat the effects of COVID-19 from outside the
European Union ("EU") without the payment of Customs Duty and VAT from20 January 2020 to31 July 2020 .
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