Tax residence rules for individuals and companies – Ireland and foreign
International Tax Treaties
Purpose – treatment of employment and pension income, self-employed income, dividends,
royalties and interest – sample treaties – Ireland-UK; Ireland-US; Ireland-Switzerland
European Union Tax Law
The VAT Directive, the Parent-Subsidiary Directive; the Interest and Royalties Directive; EU tax harmonisation – Common Consolidated Tax Base (CCTB); the European Court of Justice (ECJ) and select ECJ decisions
UK Tax I
Income tax, corporation tax, capital gains tax – non-domiciliaries, capital allowances, tax planning
UK Tax II
Inheritance tax, stamp duty land tax, VAT, national insurance contributions; tax legislation
and case law
Taxation in France, Germany, Italy, Spain, Portugal
Taxation in Belgium, Luxembourg, Denmark, Netherlands, US
Controlled Foreign Companies (CFC) legislation
Taxation in the USA
Individuals, companies – the IRS and tax compliance
Transfer Pricing
Provisions in treaties – provisions in domestic law (US, UK, Ireland)
Tax Havens
Isle of Man, Jersey, Guernsey, Gibraltar, Netherland Antilles, Bahamas, Cayman Islands,
Antigua, Andorra, Monaco, British Virgin Islands, Hong Kong, Malta, Liechtenstein; tax
information exchange agreements
Case Studies
Individuals and owner-managed businesses, trusts and estates, VAT, multinational
corporations