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Archive for Europe, Middle East

EU & U.S. Sign “Umbrella” Agreement To Protect Personal Data

William Byrnes

The EU-U.S. Ministerial Meeting on Justice and Home Affairs, hosted by the Netherlands Presidency of the Council of the European Union, took place in Amsterdam.

Signing of the “Umbrella” agreement represented a major step forward in EU-U.S. relations. The agreement sets high standards for the protection of personal data transferred by law-enforcement authorities.

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Spotlight On Expatriate Tax Experts – September 21st 2015 – Internet Tax Summit

With an estimated 8.7 Million expatriates living around the world, many are unaware of their U.S. tax filing obligations. For those following the issues surrounding FATCA, they are well aware that expatriates are angry and scared. For the two-thirds of the U.S. expatriates who are still unaware, we bring knowledgeable experts who will explain what is happening and get you up to date at the Internet Tax Summit scheduled September 21-25th 2015. The first day of the Internet Tax Summit, expatriates will be able to go online and learn what is happening from tax experts, get answers, and get the help they need.  You can expect this historical, free online event is certain to get millions of expatriates up to speed on the only country in the world with citizen based taxation. We promise the information you learn will be STUNNING! Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part VI (Final)

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

6. Capital Gains Tax – Finance Act 2014 – Vodafone Shareholders – eBrief no. 107/14 (24th December 2014).

On 14th May 2014 the Irish Revenue Authorities issued a detailed Tax Briefing outlining the tax treatment of the Vodafone Return of Value to its Shareholders. I wrote an Explanatory Blog, which was published on this site on 16th May 2014, outlining the comprehensive guidance on the calculation of the base cost for Capital Gains Tax purposes. In my Blog, I discussed the Income Tax Treatment for shareholders who opted for “C Shares”: Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part V

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

5. Relevant Contracts Tax – Revised Penalties from 1st January 2015 for the failure of a Principal Contractor to operate R.C.T. correctly on relevant payments to a contractor – eBrief no. 110/14 (24th December 2014)

Before we examine this guidance document, I will briefly explain the Relevant Contracts Tax system in Ireland.

What is Relevant Contracts Tax (R.C.T.)?

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Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part IV

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

4. Guide to the Capital Acquisitions Tax Treatment of receipts by children from their parents for their support, maintenance or education – eBrief no. 109/14 (24th December 2014).

As you are all aware, Capital Acquisitions Tax is the tax levied on gifts and inheritances received by individuals where the value of the gift/inheritance exceeds that individual’s lifetime tax free threshold amount.

Section 82(2) of the Capital Acquisitions Tax Consolidation Act exempts from tax “normal Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part III

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

3. Guidance on Compensation Payments under Section 2B of Employment Permits Act 2003 – eBrief no. 112/14 (24th December 2014)

The best starting point in relation to understanding the tax treatment of awards/settlements is Section 192(A) Taxes Consolidation Act 1997. It can be summarised as follows:

• If the award/settlement relates to a loss of wages/salary such as a Payment of Wages Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part II

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

2. Deduction for Income Earned in Certain Foreign States (Foreign Earnings Deduction) – eBrief no. 106/14 (24th December 2014)

The Foreign Earnings Deduction (F.E.D.) was introduced in Finance Act 2012.

It was designed to encourage and incentivize individuals who perform their duties of employment in the specific countries Ireland was targeting for the purposes of business development and export growth.

In 2012 this tax relief applied to Irish resident employees who carried out significant Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Part I

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

1. Transfer of a Business to a Company (Section 600 Taxes Consolidation Act 1997 Relief and Assumption of Business Debt) – eBrief no. 111/14 (24th December 2014)

Section 600 TCA 1997 provides that Capital Gains Tax on the transfer of a business and all its assets to a company may be deferred providing four conditions are met:

1. The business is transferred as a going concern
2. The transfer is for bona fide commercial reasons and not for the purposes of tax avoidance Read more

Revenue Guidance Documents Following Finance Act 2014 (Ireland) – Introduction

A number of Revenue Guidance Documents have been introduced following Finance Act 2014 being signed into law on 23rd December 2014.

This article will be focusing on the following documents:

1. Part I – Transfer of a Business to a Company (Section 600 Taxes Consolidation Act 1997 Relief and Assumption of Business Debt) – eBrief no. 111/14 (24th December 2014)
2. Part II – Deduction for Income Earned in Certain Foreign States (Foreign Earnings Deduction) – eBrief no. 106/14 (24th December 2014)
3. Part III – Guidance on Compensation Payments under Section 2B of Employment Permits Act 2003 – eBrief no. 112/14 (24th December 2014) Read more

Compliance 2014 – Capital Gains Tax – Ireland

If you’ve already made or about to make a disposal of a capital asset (e.g. certain shares, an investment property, a business, etc.) anytime between 1st January and 30th November 2014 you will be obliged to pay your Capital Gains Tax by 15th December 2014.

If you decide to wait and dispose of your asset between 1st December and 31st December 2014 then your payment will be due by 31st January 2015.

What happens if you miss these deadlines?

Interest of 0.0219% per day will be applied to all late payments of Capital Gains Tax.

What happens if you make a gain in the first part of the year and a loss in the second part?

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Are There Any Incentives For Employees of U.S. Employers Seconded To Ireland?

Special Assignee Relief Programme

The Special Assignee Relief Programme or S.A.R.P. applies to secondments in Ireland in 2012, 2013 and 2014 and lasts for five calendar years for each employee.

How does an employee qualify for this relief?

To qualify, the employee:

• Must work full time with the seconding employer (i.e. the U.S. employer) before the secondment for at least twelve months prior to moving to Ireland.
• Must not be Irish resident in the five years prior to the secondment. Read more

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