Appeal against High Court judgment [2024] IEHC 569 regarding application of group relief s411 TCA 1997
Appeal following [2024] IEHC 565 examining the legal burden of proof in relation to the issue of residence
Appeal by way of case stated TAC determination (128TACD2023) regarding the formulation and amendment of questions in the case stated rather than the substantive tax matter
Appeal from the judgment of the High Court ([2023] IEHC 555) - case stated from a determination of the Tax Appeal Commissioner (27TACD2021) to the effect that the exercise of a put option by a group of investors was chargeable to tax stamp duty under s31A SDCA 1999
Appeal from the judgment of the High Court ([2024] IEHC 92) regarding case stated - TAC determination (81TACD2022) concerning a holding company’s entitlement to input VAT recovery in respect of ongoing activities and a number of transactions s12 VATCA 2010, s12 VATCA 2010, s33 VATCA 2010, s34 VATCA 2010, s59 VATCA 2010, s61 VATCA 2010
Appeal from the judgment of the High Court ([2023] IEHC 764) regarding “date of disposal” for CGT purposes of the Appellant’s fishing vessel together with the vessel’s associated capacity tonnage and in particular whether the said disposal took place the date when Entrepreneurial Relief of 13% was introduced entitling him to claim relief on CGT liability, s577AA TCA 1997
Appeal by way of case stated TAC determination (134TACD2023) regarding incorporation of a quarrying business from a sole trader and assessment to income tax
Case that commenced in 1997, when the taxpayer challenged Revenue’s assertion that a partnership agreement involving the acquisition, distribution and licensing was a tax avoidance transaction. This case examines the extent of the taxpayers right to appeal s811 TCA 1997; s957(1)(c) TCA 1997
Appeal by way of case stated 28TACD2024, dealing with the application of EWSS and requirement that a business would experience a 30% reduction in turnover, s28B EMPI Act 2020
Meaning of reconstruction for company law purposes - predetermined next step