Irish Tax Institute AITI Chartered Tax Adviser (CTA)

128 Pages·2013·6.32 MB·English

2013 VOLUME 26 NUMBER 4 ISSN 1649-7899
Irish Tax Review
The Journal of the Irish Tax Institute
www.taxinstitute.ie
Harvard Kennedy School
and Irish Tax Institute Host
Global Tax Policy Conference
In this Edition:
 Department of Finance Review of Ireland’s  Getting Their Own Back: Share Buy-backs
Research and Development Tax Credit 2013 Revisited – Tax and Legal Considerations
 Timely Tax Considerations and Actions  Succession Planning: Family Partnerships and
 Pension Limits After Finance (No. 2) Bill 2013 Discretionary Trusts – Tax and Legal Issues
 Section 811 TCA 1997 – Overview of Notices of Opinion Issued  The UK Has a New GAAR – As Strong as Ours?
 The Irish Holding Company Regime  Companies Bill 2012: Effect on Corporate Restructurings
 Debt in Death: Recent Trends in Estate Litigation

3
2013 Number 4 Quickfi nd
Irish Tax Review Contents
Editor: Julie Burke
Editorial Board: Messages from Irish Tax Institute
Michael Ryan (Chairperson),
Julie Burke, Colm Browne, 4 Digest
Helen Byrne, Eamonn Coates,
6 President’s Pages
Gabrielle Dillon, Eddie Doyle,
John Fisher, Gerard Guilmartin, 8 Chief Executive’s Pages
Carol Hogan, Tom Maguire,
Thalia O’Toole, George Thompson
Regular Features
Copyright © Irish Tax Institute 2013.
All rights reserved. No part of this
11 Legislation & Policy Monitor
publication may be reproduced.
Published by/Origination by: Deirdre Daly, Tax Manager , Irish Tax Institute
Irish Tax Institute, 17 Tax Cases
South Block, Longboat Quay, Frank Carr
Grand Canal Harbour, Dublin 2
29 Compliance Deadlines
Tel.: [phone]
Fax: [phone] David Fennell, Director, EY
E-mail: [email protected] 32 International Update
Website: www.taxinstitute.ie Joan O’Connor, Tax Partner, Deloitte
Printed by: Spectrum Print
Louise Kelly, Tax Director, Deloitte
Management
Copy-edited by: 39 VAT News
Aisling Flood Gabrielle Dillon, Director, Dermot O’Brien & Associates
In-house origination by:
43 Accounting Developments of Interest
Judy Hutchinson
Aidan Clifford, Advisory Services Manager, ACCA Ireland
and Eugene Tyson
Design and layout by:
Eugene Tyson Feature Articles
Production Liaison:
Judy Hutchinson
47 Department of Finance Review of Ireland’s Research and
Advertisers please contact:
Development Tax Credit 2013
Jackie O’Dowd
Kate Levey, Assistant Principal, Business Tax Section,
Tel: [phone]
Email: [email protected] Department of Finance
Mairéad Ross, Administrative Officer, Business Tax Section,
2013 VOLUME 26 NUMBER 4 ISSN 1649-7899
Department of Finance
Irish Tax Review2013 VOLUME 26 NUMBER 4 IThe Jorurnal iof thes Irish Tahx Instit uteTaxan dH RaIrrivsaher dT aKxve Innniseteditwyuw wtS.wteaxci nHhstituoote.osietl 53 TSaimshealy K Tearixn sC, oTnasxi dDeirreacttioorn, sG aranndt AThctoironntson
Global Tax Policy Conference
57 Pension Limits After Finance (No. 2) Bill 2013
Tony Gilhawley, Director, Technical Guidance Ltd
64 Section 811 TCA 1997 – Overview of Notices of Opinion Issued
Helen Byrne, Senior Manager, EY
In tSTDRTPhhieeeeimsencsp t eesaEIiilarordoyitrnsi nmcTth h 8aiLe o H1xianmn1 ontC :T lidoodtC sfnDi An FsAe gii1fnvd9 tCeaee9lonrro7a mcFp te–ipimn oORaaneenvnnsveyc tiar eeRTvn wea(ideNgx owA oiCmf c. or It2eerfie) odN lBniaotsi ntl2lid 0c2’e1s03s 1 o3f Opinion Issued  GRSDTCDhoueieesmevcbtctci tUrpise neiiaKsntgtnesi DHoTiideoneah –snaase rT BtPiahyrail l:ONaxTl Rn rew2auenwn0nscid1 n teGB2s gnLAa: :–et cEA F gTkTfRaraaf:eme lx–Sn cC ihaAtdloy anossn rd PniSesn aL itCB drreEotoeugsnrnryptaeaga-olrbt t siraIeaosahs cnsLti keOpusits seuRi g sraesans?tdtiro uncturings 69 The Irish Holding Company Regime
ISSN 1649-7899 Padraig Daly, Partner, Daly Partners
December 2013, Volume 26, Number 4 73 Getting Their Own Back: Share Buy-backs Revisited – Tax and Legal Considerations
Disclaimer: The Irish Tax Niall Cogan, Senior Manager, Tax & Legal Services, PwC
Institute can accept no Graham Wright, Senior Manager, Tax & Legal Services, PwC
responsibility for the accuracy
78 Succession Planning: Family Partnerships and Discretionary Trusts – Tax and Legal Issues
of contributed articles or
statements appearing in this Tracey O’Donnell, Senior Manager, Deloitte
publication, and any views or Joanne Whelan, Tax Partner, Deloitte
opinions expressed are not 85 The UK Has a New GAAR – As Strong as Ours?
necessarily subscribed to by the
Tom Maguire, Director and Tax Technical Centre Leader, PwC
Institute.
No responsibility for loss or 96 Companies Bill 2012: Effect on Corporate Restructurings
distress occasioned to any Ruairí Mulrean, Partner, LK Shields Solicitors
person acting or refraining
104 Debt in Death: Recent Trends in Estate Litigation
from acting as a result of the
material in this publication can Dearbhla Cunningham, Barrister-at-Law
be accepted by the authors,
contributors or publisher.
Irish Tax Institute News
Following publication of an article
or other feature, it may happen
that additional information or a 112 Global Tax Policy Conference: A Summary Review
correction will later be published 117 Irish Tax Institute Events
so the reader is advised to refer
to subsequent issues. 126 News and Moves
4 Digest 2013 Number 4 Digest 5
» The UK First-Tier Tribunal applied the Halifax doctrine in the case of
Julian Massey and Beryl Massey t/a Hilden Park Partnership.
» In the University of Huddersfi eld Higher Education Corporation case
the UK First-Tier Tribunal rejected an attempt to apply the Halifax
abuse doctrine to a VAT plan admitted to be a tax-avoidance plan
without commercial purpose.
» The ECJ ruled in Fiscale Eenheid PPG Holdings that the company
Digest was entitled to input credit on costs invoiced to it in relation to the
provision of services by a third party to a separate pension fund
created by PPG.
Julie Burke
Editor » The UK First-Tier Tribunal held in the case of Rapid Sequence Ltd that
the supply of locum dentists was not an exempt supply of medical
Legislation & Policy Monitor services but a standard-rated supply of staff.
» The ECJ Advocate-General has given an opinion in the most recent
» Deirdre Daly details Bills presented, Acts passed and Revenue e-Briefs
FII Group Litigation case from the UK.
issued, as well as selected Statutory Instruments made, in the period
21 July to 10 October, providing a comprehensive overview of key » The case of Denis O’Brien was heard in the High Court and found that
developments and policy news. Mr O’Brien did not have a permanent home available to him in Ireland
in a relevant tax year despite owning a vacant residential property
Tax Cases here that was habitable for a brief period in the year.
Frank Carr
Compliance Deadlines
» The ECJ has given a judgment in the case of Rodopi-M 91 OOD, which
» David Fennell details key tax-fi ling deadlines for December 2013 to
concerned the application of penalties for VAT over-deduction.
February 2014.
» The ECJ has decided a case involving Belgium’s notional interest
deduction and freedom of establishment. International Update
» The UK First-Tier Tribunal case of Prescription Eyewear Ltd is an
Joan O’Connor and Louise Kelly
excellent summary of case law to date on the VAT exemption for
» The OECD’s Action Plan on Base Erosion and Profi t Shifting has
medical care, as well as the rules on single versus separate supplies.
been fully endorsed by G20 Finance Ministers and the Heads of
» The UK First-Tier Tribunal case of Clive Bowring concerned a UK tax
Central Banks.
plan called a “fl ip-fl op”, which is aimed at avoiding the consequences
» At a recent informal ECOFIN meeting, EU and OECD offi cials agreed
of taking benefi ts from an offshore trust that has or will have capital
to foster the progress in developing a global standard of automatic
gains.
exchange of tax information.
» The ECJ has ruled in the case of AES-3C Maritza East that a company
» The New Zealand Inland Revenue has released its third report on the
providing free transport to persons working on its behalf but who
taxation of multinational enterprises and base erosion.
were not its employees is entitled to input credit in respect of the
costs of the transport. » The UK Prime Minister has announced that details of the benefi cial
ownership of UK companies will be made publicly accessible.
» The UK Court of Appeal case of Mertrux Ltd considered whether sums
received for the transfer of a business and for the early cancellation » The European Commission issued its draft report in relation to the
of an agency were for goodwill. UK patent box regime. The Commission has determined that the
patent box regime violates two of the fi ve criteria for evaluating
» David Baxendale Ltd lost a UK VAT appeal in 2009 and sought to
special tax regimes.
appeal an assessment on identical grounds to those on which it
lost that appeal. The First-Tier Tribunal rejected the second appeal » On 8 October 2013 the French Finance Minister announced that the
as an abuse of process. Government has abandoned plans to introduce a 1% tax on gross
operating surplus.
» In the Medicom SPRL case the ECJ considered a situation where
Medicom acquired a building that it used partly for its business and » The Hungarian Government has announced proposed changes to
partly to house managers and their families rent-free. the participation exemption regime and the taxation of company
migrations to Hungary.
» The UK Court of Appeal decision in Pendragon explored the anti-abuse
doctrine of the ECJ as developed in Halifax and later cases. » On 4 October 2013 the Dutch State Secretary for Finance proposed an
amendment to the 2014 Budget to restrict intra-group corporate tax
2013 Number 4 Digest 5
avoidance by requiring all companies that pay and collect interest and » The Australian Administrative Appeals Tribunal has judged in AP
royalties to meet substantial-activity requirements to avoid penalties. Energy Investments Limited v Commissioner of Taxation that shares
» The European Council Legal Service has drafted an internal legal held in an Australian mining company that were sold between two
opinion on the proposed fi nancial transaction tax, which has raised Chinese companies were not deemed to relate to property, and thus
concerns about the territory to which the FTT extends and the potential the sale was not subject to capital gains tax.
infringement of the tax rights of non-participating Member States. » A corporate income tax reform Bill has been introduced by the
» As a result of the decision of the ECJ in the case of Tate & Lyle Argentinian Government that proposes withholding tax of 10% on
Investments, the Belgian Government has released a circular on distributions and capital gains tax of 15% on unlisted shares and
the provisions for granting a refund of dividend withholding tax. stock transactions, which would be payable by both residents and
non-residents.
» The European Commission has asked for comments on the new
Spanish tax scheme regarding the buying of shares in foreign » On 16 August 2013 the Canadian Department of Finance released
companies. The scheme allows tax deductions for the acquisition for public comment draft legislative proposals to change the foreign
of shares in foreign companies. affi liate “dumping” rules.
» The Spanish Government has published the draft Bill for the Support » On 1 October 2013 the Japanese Government announced amendments
of Entrepreneurship and Its Internationalisation in an attempt to to the consumption tax and corporate income tax rates.
boost falling Exchequer revenue.
VAT News
» Luxembourg published a circular on the application of its minimum
» Gabrielle Dillon gives us the latest VAT news.
corporate income tax.
Feature Articles
47 Department of Finance Review of Ireland’s Research 73 Getting Their Own Back: Share Buy-backs Revisited –
and Development Tax Credit 2013 Tax and Legal Considerations
» Kate Levey and Mairéad Ross detail the Department of Finance review » Niall Cogan and Graham Wright focus on the tax analysis for an
of the R&D tax credit carried out this year. The article outlines the unquoted company and its shareholders when the company reacquires
approach that was taken to the review and sets out the key fi ndings its own shares.
from a tax perspective, as well as the tax policy recommendations.
78 Succession Planning: Family Partnerships and
53 Timely Tax Considerations and Actions Discretionary Trusts – Tax and Legal Issues
» Sasha Kerins summarises, under each tax head, a number of consid- » Tracey O’Donnell and Joanne Whelan outline the tax and legal issues
erations and deadlines relevant to taxpayers for 2013, including relating to family partnerships and discretionary trusts when used
the effects of some 2014 Budget announcements by the Minister in succession planning.
for Finance.
85 The UK Has a New GAAR – As Strong as Ours?
57 Pension Limits After Finance (No. 2) Bill 2013
» Tom Maguire analyses the general anti-abuse rule introduced by the
» Tony Gilhawley summarises the operation of Part 30, Chapter 2C, TCA UK’s Finance Act 2013, which received Royal Assent on 17 July 2013.
1997, which taxes retirement benefi ts taken in excess of a specifi ed
96 Companies Bill 2012: Effect on Corporate
limit, and highlights important changes contained in Finance Bill
Restructurings
(No. 2) 2013.
» Ruairí Mulrean considers some of the changes in the Companies Bill
64 Section 811 TCA 1997 – Overview of Notices of Opinion
2012 that will have implications for how corporate restructurings
Issued
are undertaken and are most relevant to Chartered Tax Advisers.
» Helen Byrne give an overview of the notices of opinion that Revenue
104 Debt in Death: Some Recent Trends in Estate Litigation
has issued under the provisions of s811 TCA 1997, which will be of
» Dearbhla Cunningham focuses on issues concerning creditors’ claims
signifi cant interest to Chartered Tax Advisers.
to a deceased’s estate, the appointment of an administrator to the
69 The Irish Holding Company Regime
estate by a creditor, and the removal of an executor, as illustrated
» Padraig Daly considers the taxation benefi ts of the Irish holding in recent litigation. These legal issues are inextricably linked to tax
company regime. issues and are relevant to Chartered Tax Advisers.
6 President’s Pages 2013 Number 4 President’s Pages 7
President’s
Pages
Helen O’Sullivan
Irish Tax Institute President
The past three months have been an extraordinary period of success the OECD Centre for Tax Policy and Administration, who addressed
for the Irish Tax Institute, with a huge amount of activity on the most conference delegates, welcomed the publication of the Strategy and
pertinent national and global tax issues. commended Ireland for its commitment to “play[ing] by the rules”
and its contribution to shaping tax policy and implementing it fairly.
Global Tax Policy Conference in Association
with Harvard Kennedy School CTA Network – Nationwide Activity this Autumn
The hugely successful Global Tax Policy Conference on 17–18 October Although our CTA Network has been growing since its launch in May,
was the pinnacle of the Institute’s activity this season and the culmina- the pre-Budget 2014 season saw the real activity and engagement
tion of over a year’s work. By collaborating with the Harvard Kennedy commencing nationwide. Hundreds of CTAs attended the events,
School and bringing the leading global names in tax to Dublin, we along with the Chambers’ business/SME members and local TDs and
copper-fastened the Irish Tax Institute’s status as the leader in tax. Senators. The events ensured that the Institute and its CTA members
communicated the major tax issues of concern and that the CTA brand
The coverage and profi ling of the event and the themes that emerged
and the profession were well promoted among SMEs.
were signifi cant not only for the Institute and its members but also for
“Ireland Inc.” in front of a global audience of over 260 delegates from Given my own personal background and tax career, I was very happy
30 countries. This positive positioning of Ireland’s tax system on the to launch the CTA Corporate Network in November, at a social event
global stage was underpinned by the announcement by Minister Noonan for corporate members where the guest speaker was Colm Ó Nual-
of Ireland’s International Tax Strategy two days before the conference. láin, former Finance Director of Grafton Group plc. The Network will
meet regularly throughout the year and will provide members from
The publication of the Strategy saw the Irish Government establish its
the corporate sector with a forum to network with their peers in an
credentials as a highly engaged and proactive contributor to the corpo-
informal environment and discuss issues that are impacting on them
rate tax reform initiatives currently being undertaken at international
in their daily roles. If there are any issues that you would like to raise
level, not least of which is the OECD’s BEPS project. If the Strategy
in relation to the sector, I would encourage you to contact Martin
could be summed up in one expression, it would be Minister Noonan’s
Lambe in the Institute.
declaration that “I want Ireland to play fair – as we have always done
– and I want Ireland to play to win”. Pascal Saint-Amans, Director of
2013 Number 4 President’s Pages 7
I would like to thank all of our CTA Network Chairs and all network successfully rolled out at the end of September and has already been
members who have embraced it and given of their time and support. used by students pursuing the CTA and Tax Technician qualifi cations,
The CTA Network has come into its own in recent weeks, with phenom- attendees at the Global Tax Policy Conference and CTA members
enal engagement by members on the Pay & File date change issue. I pursuing the Institute certifi cate programmes. The feedback for the
cannot thank members enough for giving of your time to engage on system has been overwhelmingly positive, providing invaluable support
this vital issue with your local representatives at the busiest possible for students throughout their studies. Members will also benefi t
time of year for you and your practices. greatly from the new LMS, with the Institute’s entire suite of online
CPD programmes available on the platform.
Budget 2014
Unusually, as I write in November, we are looking back on the publi- The next phase of investment in technology will see us turn our atten-
cation of next year’s Budget. The Institute welcomed the Budget’s tion to delivering improvements in the TaxFind platform. With the
determination to grow and expand Irish businesses once again and to advent of smart and mobile technologies, the TaxFind platform needs
help people create and retain jobs in Ireland. A number of measures to evolve, and improvements will be rolled out in 2014. The Institute
were particularly welcome in terms of the Institute’s priorities and has always embraced technology to deliver innovative products and
pre-Budget activity, including entrepreneurs’ CGT relief, the removal services to members.
of the Employment and Investment Incentive from the high-earners’
Corporate Governance and Council
restriction and the introduction of the Start Your Own Business relief.
Peter Brennan, who was co-opted to Council two years ago, has decided
A hugely welcome measure was the Minister’s announcement of a
to step down from Council, and I would like to thank Peter for his
consultation on reform of the appeals system in 2014. This consulta-
invaluable contribution and insight during his term. While Council is
tion is central to ensuring that taxpayers have a fair, accessible and
sorry to see Peter step down, I am delighted to announce that Frank
effi cient avenue of appeal.
Ryan, former CEO of Enterprise Ireland, has agreed to join Council.
Revenue Issues Frank’s record, not least at Enterprise Ireland, is most impressive,
The contractors’ project remains a huge issue for you, the members, and the Institute should benefi t greatly from his domestic and inter-
and accordingly, for the Institute. The Institute recently made a submis- national experience.
sion to Revenue setting out the concerns we have. We will continue
Season’s Greetings
to engage on this issue through the TALC structure and other suit-
As these are my last President’s Pages for 2013, I would like to take this
able avenues.
opportunity to thank you, our members, for your unstinting support
The agendas of Main TALC and the sub-committees continue to include throughout the year. I wish you and yours a very happy Christmas and
the tax administration issues facing practitioners. The Institute will hold a peaceful and prosperous New Year.
the Chair of Main TALC in 2014, and we look forward to continuing to
E
contribute to real progress on real issues.
Strategic Plan
William Claffey
Council and management are very focused on implementing the latest
R.I.P.
iteration of our Strategic Plan, which will take us up to 2016 and the eve
of the 50th anniversary of the founding of the Institute, in 1967. I am
All involved with the Institute were very sad to hear of the
happy to tell you that very good progress is being made on delivering
sudden death of William Claffey. William, who worked with
the plan’s objectives across a wide range of issues. A consistent theme
Matheson, was an associate member of the Institute.
in the Strategic Plan was to increase and improve the use of technology
The Institute extends its deepest sympathy to
to provide members with innovative tax products and services that
William’s family, friends and colleagues.
support them in their day-to-day roles and are device-independent.
Learning Management System
E
I am pleased to say that the first element of the Strategic Plan’s
technology initiative, a learning management system (LMS), was
8 Chief Executive’s Pages 2013 Number 4 Chief Executive’s Pages 9
Chief Executive’s
Pages
Mark Redmond
Irish Tax Institute Chief Executive
Pay & File Whatever the outcome of our collective efforts, there can be no doubt
As I write these words, our practitioner members are working all hours that all relevant information was presented to our policy-makers to
to ensure that their clients fulfi l their Pay & File obligations. That enable the right decision to be taken.
so many of you have also made the time to support the Institute’s
Budget 2014
information campaign on possible changes to the Pay & File regime
There were many positive measures in Budget 2014. The Institute’s
is simply incredible. On behalf of the hardworking Representations
consistent message about the need to address our high marginal
and Communications team at the Institute, I want to thank you
personal tax rates and very low entry point to the top rate compared
most sincerely.
to our international competitors is now widely shared and under-
The best policy is shaped by a process of effective consultation stood. We have also expressed concern that Ireland was becoming
where all relevant information is considered. The best administration a cold country for entrepreneurs and job creators – the Budget saw
is to be found where there is a shared understanding between the some steps in the right direction. We recommended a number of the
participants in that administration of what works and what won’t. I small-business measures contained in the Budget, such as raising
cannot think of a more important element of our tax administration the VAT cash-receipts limit to €2m and removing the Employment
system for our general practitioner base than the Pay & File regime. and Investment Incentive from the high-earners’ restriction. It will
Having the consultation process run for a few short weeks parallel be a measure of how long we have been urging reform of the Appeal
to the Pay & File deadline was far from ideal. However, minds were Commissioners when I remind members that this was a central project
concentrated and sleeves were rolled up. in Dermot O’Brien’s Presidency, and Dermot oversaw a comprehensive
and compelling report from us on why reform was needed and how
A collective effort by our President, Council, ITI staff and, most impor-
this might work. The points remain valid six years later, and we will
tantly, our members ensured that senior fi gures in Government, the
engage fully in the consultation process announced by the Minister.
Oireachtas and the public service had a comprehensive understanding
of the grave concerns of those who make the system work about the In the lead-up to the Budget we ran a nationwide series of nine
implications of the changes being proposed. When asked about the briefi ngs in our CTA Network, in association with the Chamber of
issue in the media, I drew the analogy of bringing the Leaving Cert Commerce networks. The briefi ngs were also attended by TDs and
forward by four months – why would you do that without compel- Senators and provided an ideal forum for them to hear the views of
ling reason? I also commented on the successful “public–private” the tax profession and business. The feedback from these events
partnership that exists between Revenue and the profession in has been very positive from both our members and the Chambers.
delivering 98% compliance in the Pay & File area.
We provided our full range of information services to members in
relation to the Budget. This included news alerts as the Budget
was being presented, a comprehensive TaxFax on Budget Night,
2013 Number 4 Chief Executive’s Pages 9
fully subscribed Budget Breakfast Briefi ngs in Cork and Dublin the speaker list was a who’s who of the Irish and international tax world.
morning after the Budget, and a comprehensive Budget information A summary of the conference proceedings also appears in this edition
portal on our website. of Irish Tax Review. I would like to take this opportunity to thank all
of the members who supported this landmark event for the Irish tax
CTA Programme: Cutting-Edge Technology
community, our four supporting organisations (the Chartered Institute
In previous reports to members, I spoke of Council’s commitment
of Taxation (UK), the Foundation for Fiscal Studies, PublicPolicy.ie
to make value-for-money investment in our core areas of activity,
and Revenue) and the fantastic Institute team.
and particularly our education programmes. I also spoke about our
strategy of using electronic management and delivery options to I was particularly delighted to see students from tax programmes at
give a better service to students and members. The last few weeks a number of our universities attend the conference. From speaking
have seen a transformation in how our Chartered Tax Adviser (CTA) to a few of them, it is clear that they learned a great deal and that it
and Tax Technician students experience their programmes of study. brought much of what they are studying to life.
We have successfully launched a new learning management system
Eamonn Corcoran RIP
(called Blackboard). This provides our students with 24/7 access to
The tax community was deeply saddened at the death of Eamonn
their materials, lectures, reference sources and course information –
Corcoran in August. Eamonn had been very ill but bore his illness
it also allows them to monitor their progress. Particular credit goes
with remarkable courage and his trademark optimism. Over a distin-
to my colleague Elspeth Hennessy and to Martina O’Brien’s team for
guished career in tax, Eamonn worked with Revenue and Deloitte. He
the successful introduction of this major new initiative.
was a great supporter of our Institute – Ciaran Desmond and Eamonn
We have already made good use of this innovation in the delivery of designed from scratch and delivered the very popular Practical Tax
our CPD/Certifi cate/Diploma programmes for members. for Beginners programme, which ultimately evolved into our Tax
Technici an qualifi cation.
Ireland on the Global Stage
“This has been a fantastic conference – the best conference (not Our deepest sympathies go to Eamonn’s wife, Geraldine, his family
just tax) I have attended. Superb line up of speakers, stimulating and his colleagues at IPASS, which he founded.
debate and a wonderful advertisement for Ireland.”
Best Wishes
That is a representative example of the feedback from delegates at As this is the last Irish Tax Review of 2013, I want to thank all members
our Global Tax Policy Conference, which we jointly hosted with the and students for their support and participation over the past year.
Harvard Kennedy School in Dublin Castle on 17 and 18 October. Over It has been a privilege to work with you, and I wish you and yours
260 delegates, representing more than 30 countries, attended. The the very best for Christmas and 2014.
Annual Dinner 2014
… an excellent opportunity for networking amongst fellow members,
clients and senior fi gures from the public and private sectors.
Date: Friday, 28 February 2014
Venue: Double Tree Hilton, Dublin (Formerly ‘The Burlington’)
Price: €100 per person
Dress: Black Tie
Book Before: 31 January 2014
To reserve your place please email Samantha Feely: [email protected] Tel: [phone] Web: www.taxinstitute.ie
AITI Chartered Tax Adviser
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