This unique new title is the only Irish tax publication which provides an in-depth and comprehensive analysis of the Irish tax issues arising in company reorganisations and reconstructions. The book adopts a practical approach to examining the principal considerations arising from the types of reorganisations typically undertaken by Irish companies. The text includes a number of worked examples, case studies and tax planning points relevant to this complex area.
Providing a comprehensive analysis of relevance to tax practitioners in both large and small tax firms, it considers the practical application of tax law in key areas, including:- Restructurings in the context of incorporation - Group reorganisations/reconstructions - Restructurings for sale - Share capital reorganisations - Earn outs and long term incentive schemes - Anti-avoidance - An introduction to relevant company law and accounting issues is also included.
Read an extract of Taxation of Company Reorganisations in Ireland
Table of Contents
Part 1: General Considerations and Definitions: 2 Outline of Tax-Neutral Reorganisations Transactions; 3 Pattern of Domestic Reorganisation Reliefs in Irish Tax System; 4 Company Reorganisations - Key Definitions;
Par 2: Direct Tax Treatment of Relevant Parties: 5 Overview; 6 Tripartite Reorganisations: Tax on Capital Gains; 7 Tripartite Reorganisations - Corporation Tax Issues; 8 Bipartite Reorganisations; 9 Takeovers; 10 Single Company Reorganisations;
Part 3: Other Taxes/Issues and Pre-Sale Reorganisations: 11 Other Taxes, 'Checklist' Issues and Specific Aspects of Pre-Sale Reorganisations; 12 Anti-Avoidance; 13 Multinational Reorganisations.