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Determination-184TACD2025

Tax Cases and Appeals Tax Appeals Commission
2025-07-21
A series of appeals linked to determination 42TACD2024 regarding assessment to income tax in respect of liquidation proceeds received from company not tax resident in Ireland s740 TCA 1997; s743 TCA 1997; s745 TCA 1997
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Determination-181TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-11-13
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-169TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-11-05
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-171TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-11-05
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-155TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-10-07
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-157TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-10-07
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-158TACD2024

Tax Cases and Appeals Tax Appeals Commission
2024-10-07
Appeal regarding material interest in a fund that was not tax resident in Ireland (see also 104TACD2024 and 105TACD2024; 107TACD2024-117TACD2024, 42TACD2024, 143TACD2024 - 147TACD2024; 137TACD2024 - 141TACD2024; 155TACD2024 - 159TACD2024) s740 TCA 1997, s743 TCA 1997
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Determination-135TACD2023

Tax Cases and Appeals Tax Appeals Commission
2023-10-06
Appeal regarding application of the four-year statutory limitation period, s865 TCA 1997
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Determination-127TACD2022

Tax Cases and Appeals Tax Appeals Commission
2022-10-03
Appeal against two alternative assessments made in relation to the same transaction. The assessment to capital gains tax relates to the denial of retirement relief on a sale of shares and a refusal to treat a share-for-share exchange as a reorganisation of share capital on the basis that the transactions were not made for bona fide commercial reasons and the main purpose or one of the main purposes of the transactions was to avoid a liability to tax. The assessment to income tax relates to the refusal to allow a sale of shares in a close company to be treated as a capital transaction on the basis that it was not a bona fide commercial transaction and was part of a scheme or arrangement the purpose or one of the purposes was the avoidance of tax, s584 TCA 1997; s586 TCA 1997; s598 TCA 1997; s817 TCA 1997
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Determination-14TACD2021

Tax Cases and Appeals Irish Tax Institute
2021-01-21
Appeal regarding income tax assessment and entitlement to private residence relief
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