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An analysis by William Fry
Our Irish firm, William Fry, explores the implications of the successful appeal by a taxpayer against an assessment to corporation tax of €25m.
Ireland’s Revenue Commissioners raised the assessment on the basis that the proceeds from a waiver of an intercompany loan constituted profits or gains of the Appellant’s trade and was a taxable receipt for corporation tax purposes.
The Appellant successfully appealed Revenue’s assessment, arguing that the loan was capital in nature and that the waiver of the loan was a capital transaction and did not give rise to corporation tax.
Read the full article here.
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