Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2019, which includes significant amendments in relation to the Tax Consolidation Act 1997 including exit tax, transfer pricing, and hybrid entities and instruments. Contents include: Statutory interpretation; What is an asset; What is a disposal; Persons chargeable; Married couples and civil partnerships; Taxation of partnerships; Computational rules; Shares; Financial instruments; Debts; Trusts; Anti-avoidance; Companies; Residence; Foreign tax matters; CA 2014 transactions.
Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2020. Contents include: Statutory interpretation; What is an asset; What is a disposal; Persons chargeable; Married couples and civil partnerships; Taxation of partnerships; Computational rules; Shares; Financial instruments; Debts; Trusts; Anti-avoidance; Companies; Residence; Foreign tax matters; CA 2014 transactions.
"Given the depth of detail, the comprehensive treatment of the subject, and the clear explanations of each area of this important tax for practising solicitors, this is undoubtedly the reference book for Irish capital gains tax.” The Law Society Gazette (review of the 2020 edition). Provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2022. This title is included in Bloomsbury Professional's Irish Tax online service.
“Given the depth of detail, the comprehensive treatment of the subject, and the clear explanations of each area of this important tax for practising solicitors, this is undoubtedly the reference book for Irish capital gains tax.” The Law Society Gazette (review of the 2020 edition). Provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2021. This title is included in Bloomsbury Professional's Irish Tax online service.
Taxation of Company Reorganisations, Sixth Edition is an essential reference source for tax advisers which covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. Written by authors with more than fifty years' experience of dealing with clients from small owner-managed businesses to multinational corporate groups, this title includes guidance on the full range of corporate transactions and is applicable to a wide number of organisations. While there is comprehensive coverage of the technical and theoretical meaning of the legislation, the authors have also drawn on their vast practical experience, derived from many years of transaction-based work. This Sixth Edition has been brought fully up to date with recent Finance Acts including FA 2019 and the proposals for FA 2020 that were published in July 2019. It has been reviewed for company and European law and has been updated in relation to the following: - Changes to substantial shareholding exemptions in Finance (No. 2) Act 2017 - Changes to EIS, SEIS and VCT investment schemes in FA 2018 - The introduction of LBTT in Scotland and LTT in Wales - Stamp duty changes proposed for FA 2020 - Enhanced material on the taxation of goodwill and loan relationships on a reorganisation Cases updated since the last edition include: - Gallaher Ltd v Revenue and Customs Commissioners [2019] UKFTT 207 (TC) (on application of s171 TCGA 1992) - Hancock [2019] 1 WLR 3409 (Supreme Court decision) - Trigg [2018] EWCA Civ 17 (Court of Appeal decision)
The book provides a clear introduction to international taxation and presents its material in a global context, explaining policy, legal issues and planning points central to taxation issues, primarily from the viewpoint of a multinational group of companies. It uses examples and diagrams throughout to aid the reader's understanding and offers more in-depth material on many important areas of the subject. Traditionally published every 2 years in both print and digital formats, this content is a core requirement for student reading lists at both undergraduate and post graduate level. Fully updated to cover all new tax legislation and developments in light of the OECD BEPS project implementation, key areas to be included in this new edition are: - changes proposed by BEPS 2.0 in relation to taxation and the digital economy, including Pillar Two and the proposed new UN Model Article 12B; - further progress on the implantation of OECD Base Erosion and Profit Shifting implementation, including: -- an update on the implementation of BEPS recommendations including artificial avoidance of permanent establishment status and prevention of treaty abuse; -- the implementation of transfer pricing documentation and country-by-country reporting; -- multilateral instrument implementation; - the impact of Covid-19 on international taxation; - further developments in European direct taxation including the transparency package, directives on anti-tax avoidance and the common corporate tax base and state aid cases (Apple in particular) and updates to the Directive on Administrative Cooperation, and the new communication on Business Taxation for the 21st Century. - Proposals in relation to the taxation of digital business, in particular the OECD's unified approach and the UN modifications to the Model Double Taxation Convention. - Proposals for a global minimum corporate tax rate to curb base erosion and tax competition.
Adopting a practical approach, and with a unique transaction-based structure and special features such as pro forma elections and checklists, this book guides you through the practical realities of a claim, rather than just presenting the bare facts of statute and case law. Legislation is comprehensively covered, but with the emphasis on interpretation and explanation, rather than mere repetition of the wording of statute. Written in plain English, and packed with examples and user-friendly commentaries, the content and advice contained within Capital Allowances: Transactions and Planning 2019/20 has been comprehensively updated to cover the key developments in this area as announced in the Finance (No. 3) Bill 2017-19, these include: New Structures and Buildings Allowance (SBA) Annual investment allowance (AIA) increase to £1 million Abolition of some environmental enhanced capital allowances Reduction in the special rate of plant and machinery allowances New case law, including SSE Generation Limited v HMRC [2018] UKFTT 416 (TC) and Glais House Care Ltd v Commissioners for HM Revenue and Customs [2019] UKFTT 59 (TC) This print edition also consolidates changes made via the previous two years' online updates, including restructuring of historical content and updated commentary. This book is essential reading for anyone incurring capital expenditure on property and looking to maximise capital allowances and related tax-related reliefs on a wide range of commercial transactions.
The fifth edition to this in-depth treatment of UK share valuations has been fully updated to contain the latest UK case law and legislation. There are new chapters on Accounting Standards, Options Valuations (including a new case study), Fair Price Assur
Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.
Capital Gains Tax 2019/20 is an invaluable title for those who deal with capital gains tax on a regular basis. It examines the current legislation and HMRC guidance in a clear, comprehensive style and covers the following: Recent developments in CGT Computation of gains and losses and special rules for particular assets CGT for partners and partnership assets CGT in the periods immediately before and after death CGT payable by trusts Charges for non-domicile or non-resident taxpayers and overseas gains Corporate gains, SSE and group reliefs Land and property including non-resident CGT Main residence relief Entrepreneurs' relief Investors' Relief Hold-over relief for gifts Roll-over relief for business assets Relief on the incorporation of a business Venture capital reliefs including SEIS, EIS and SITR Relief for losses on loans to traders and on disposal of shares Transfer of shares to an Employee Ownership Trust CGT planning and anti-avoidance rules Taking on a practical approach to the subject and concentrating on the most commonly found transactions and reliefs, the commentary in this title includes 147 examples, updated to the current tax year, and is cross-referenced to the tax legislation as well as to the HMRC manuals and to other HMRC guidance. This accessible reference guide has a user-friendly structure with 'signposts' at the beginning of each chapter to summarise key topics and 'focus points' throughout to highlight important issues. Numerous worked examples demonstrate how to apply the main principles in practice and all examples are listed in a table for quick navigation.
