Appeal by way of case stated regarding TAC determination (103TACD2023), considering the treatment of a release of a balance of a €6 million property loan taken out by a development company as a receipt of the trade, s87(1) TCA 1997
Judgment regarding treatment of personal data in a tax return in terms of “right to be forgotten” legislation
Liquidator seeking to reverse a transaction – Australian Tax Office assessments had been raised on the basis investments were indirect Australian real property assets – whether ‘Revenue Rule’ applicable on basis that liquidator’s actions would effectively enforce the revenue claims of a foreign country – indirect attempt to enforce same – no DTA provisions for enforcement – OECD convention on mutual assistance inapplicable as Ireland had reserved its application to enforcement of liabilities
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Appeal regarding application of anti-avoidance rules s811 TCA 1997
Appeal by way of case stated regarding TAC determination (01TACD2023), regarding replayment of VAT in relation to professional services in connection with the sale of the Appellant’s ‘capacity’s. s5, VATCA 2010, s6 VATCA 2010, s26 VATCA 2010, s59 VATCA 2010
Judgment from the High Court in a case involving the imposition of a civil penalty for the respondent's alleged failure to file income tax and VAT returns s1077E TCA 1997, s116(3) VATCA 2010
Appeal by way of case stated regarding TAC determination (92TACD2023) concerning how to interpret the statutory definition of a ‘proprietary director’ and application of transborder workers relief. s472(1)(a) TCA 1997, s825A(3) TCA 1997
Appeal by way of case stated regarding TAC determination (60TACD2023), regarding the tax treatment of Single Payment Scheme payments paid by the Department of Agriculture, Food and Marine to an incorporated farm and the application of the four-year statutory limitation period, s955 TCA 1997
Appeal by way of case stated regarding TAC determination (51TACD2022), concerning treatment of rental income tax treatment of an ex gratia sum from an employer s192A TCA 1997; s959AH TCA 1997
Appeal by way of case stated regarding 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