Ireland in International Tax PlanningIBFD, 2004 - 1382 էջ Revised and updated edition providing the introduction to Irish tax legislation, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Follows practical discussion of Ireland's tax breaks, beginning with a discussion of the circumstances in which a company resident or carrying on business in Ireland qualifies for the 12.5% rate of corporation tax, and continuing with the issues of the tax efficient establishment and financing of a trading presence in Ireland, whether through a subsidiary or a permanent establishment or both. Possible tax planning opportunities are then discussed, both long standing tax breaks such as relief for artists and inventors, forestry, bloodstock and foreign domiciliaries, and opportunities such as those arising from the exercise of an employment in Ireland and the employment of crew members employed on ships or aircraft by an Irish resident company. The book also discusses transfer pricing and anti-avoidance provisions both in the Irish domestic tax legislation and in tax treaties. |
Common terms and phrases
accordance activities alienator allowed amount apply arising assessment assets attributable authorities basis branch or agency capital gains tax carried chapter Commissioners company RCO computed context contract corresponding to Article defined definition derived directors discussed dividend domestic effect employment Example exempt exercised follows gain accruing given hands individual interest IRCO Ireland Ireland–State R tax Irish branch Irish corporation tax Irish income tax Irish resident Italy legislation Lord meaning Member nature non-resident OECD Commentary OECD Model Convention operations paid partnership payable payment period permanent establishment person present principles profits or gains provisions question RCO’s reason received recipient reference reference to Schedule regarded relating to Article relevant remuneration resident company respect royalty share situated subject to Irish Table tax payable tax treaty corresponding taxation trade treaty partner country treaty relief trust United withholding tax