Practices

Tax

Our expertise:

We have assisted with policy making and legislating at the highest levels and we bring this real time knowledge to our engagements ensuring innovative products and enduring results. Among our partners we have Heads of Tax from a major plc and a licensed bank and leasing company. Testament to the relevance of our knowledge, every senior member of the Tax Group sits on the Tax Committee of the key industry body relevant to their sector of expertise, so you can rest assured we know the issues of your market and how best to address them.

Key areas:

Transaction types where we benefit from cutting-edge experience include:

Corporate Transactions

• Mergers and acquisitions
• Demergers and disposals
• Reorganisations and restructurings
• Public offerings
• Private equity including venture capital

Finance Tax

• Structured finance and securitisations
• Investment and funding platforms
• Irish funds (QIAIFs (including ICAVs), CCFs, Unit Trusts etc)
• Debt issuances
• Derivatives
• Loan sales
• Aviation and asset finance
• Project finance
• Corporate banking and real estate finance
• Fintech
• Alternative finance

Real Estate and Construction

• Property investment and funding structures
• Property development and funding structures
• Structuring for investing and holding specialist properties
• Capital allowances (tax depreciation)
• Irish Real Estate Investment Trusts (Irish REITs)
• Irish Real Estate Funds (IREFs)

Advisory projects where we bring to bear our specialist knowledge include:

• Start-ups
• Inward investment into Ireland
• Betting and gaming
• Executive remuneration schemes
• Retirement and succession planning
• PAYE and PRSI management
• Transfer pricing documentation
• Tax reporting obligations (including FATCA and CRS)
• Tax compliance obligations 
• Tax policy and tax strategy documentation
• Indirect tax matters, in particular VAT minimisation strategies, VAT obligations, excise duties (including anti-dumping duties) and VRT
• Withholding tax obligations and exemptions

Our Tax Dispute Resolution group is where sound judgement and robust experience in this field will guide your business through:

• Revenue queries (including entitlement and validity issues)
• Qualifying disclosures 
• Revenue audits (strategy, management and settlement)
• Tax appeals 
• Tax cases
• Tax investigations

Key highlights include advising:

• Greencoat Renewables DAC, an international renewables fund, in connection with its tax structure and tax matters affecting the funding and acquisition of two operational ROI wind farms
• Gaelectric on tax aspects of its disposal of a windfarm portfolio to CGN Europe Energy
• Magnetar Solar Australia DAC, an international solar fund, in connection with its tax structure and tax matters affecting its funding and acquisition of Australian solar assets
• Deutsche Bank - London branch in connection with the Irish tax aspects of the acquisition, holding and disposal or workout of various portfolios of non-performing commercial and residential property loans
• DBRS, a credit rating agency, on Irish tax matters relevant to the rating by them of various debt issuances by various Irish Issuers
• a selection of PLCs in connection with managing tax in a multilateral environment including in particular; advising on best practice in terms of managing tax governance, assisting Boards with setting tax strategy, assisting with effective tax rate management, and advising on how best to manage tax risk including in particular compliance risk, structural risk and reputational risk
• a major global financial services business at the Tax Appeals Commission
• numerous betting and gaming operators on the establishment of betting (retail and online), gaming, exchange and lotteries operations in Ireland
• a key player in the fish processing industry in relation to designing and implementing an exit strategy
• a major international engineering group in connection with formulating a management buy in strategy 

View our Tax Disputes and Investigations brochure here.