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Determination-59TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-05-17
Appeal regarding cost of Share Based Awards for transfer pricing purposes and interpretation of sections 825C and 825D. S835 TCA 1997, s835D TCA 1997, s 959AA TCA 1997
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Determination-48TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-03-20
Appeal regarding treatment of expenses incurred during a potential change in ownership as expenses of management, s83 TCA 1997
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Determination-47TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-03-12
Appeal regarding treamtent of royalty income linked to intellectual property s76A TCA 1997, s77 TCA 1997, s81 TCA 1997, s836 TCA 1997, Sch 24 TCA 1997
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Determination-16TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-01-18
Appeal regarding refusal of claim for an R&D tax credit as it was made out of time, s766 TCA 1997
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Determination-162TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-12-21
Appeal regarding application of R&D credit for animal breeding s766 TCA 1997
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Determination-151TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-11-10
This appeal relates to a previous determination, 99TACD2023, whether a payment was remuneration or a preferential loan. S81 TCA 1008, s112 TCA 1997, s122 TCA 1997
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Determination-122TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-09-23
Appeal considering if a capital contribution was allowable as enhancement expenditure, whether selling fee was an allowable cost and whether the sale of rights dividends had the effect of transferring a base cost, s31 TCA 1997, s78 TCA 1997, s546A TCA, s547 TCA 1997, s548 TCA 1997, s549 TCA 1997, s557 TCA 1997
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Determination-127TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-09-29
Appeal regarding amount of chargeable gains accruing to a company on disposal of a property, s561 TCA 1997
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Determination-128TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-09-29
Appeal regarding treatment of foreign royalty withholding tax (RWHT) as a deductible expense, s81 TCA 1997, s77 TCA 1997, s826 TCA 1997, Schedule 24 TCA 1997
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Determination-103TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-07-20
Appeal regarding tax treatment on forgiveness of an outstanding loan facility, s76A TCA 1997, s87 TCA1997
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