Please enable JavaScript.
Coggle requires JavaScript to display documents.
Corporation Tax Introduction (Finance Act 2014 (Prior to 2014 company…
Corporation Tax
Introduction
Charge to
Corporation Tax
Non Residen
t with Permanent Establishment
PE
Examples of PE - factory office located in Ireland
German company with factory in Ireland but no Ltd Co. in Ireland will pay tax in Ireland on profits generated in Ireland
Company
Residence
Not same as Chapter 1 for individual
Statutory Test
Incorporated and registered with CRO
French Company with Ltd co subsidiary in Ireand
Double tax Treaties will determine the main country in which company is liable to pay tax.
Reduce double taxation
Central Management and Control Test
It is not set out in tax legislation
Based on case Law
Where is strategic control
Directors based, directors meetings location
Where are books of accounts maintened
Resident in Ireland
-
Worldwide Profits
Finance Act 2014
Prior to 2014
company incorporated in Ireland
But
centrally managed and controlled
outside
of Ireland
Not Resident in Ireland
Why might an Irish subsidiary incorporated pre 2014 of American multinational be considered stateless?
Trading Exemption
Company controlled by persons resident in
Eu Member state or double taxation agreement country
Control is 50% or more of shares
Exempt :no_entry: from Irish Corporate Taxation
December 2020
All companies incorporated in Ireland
Automatically Tax Resident
in Ireland
Except if Double Tax Treaty based on parent location
Company Incorporated Since 2014
Tax Resident in Ireland
Unless
trading exemption
below applies
Rates of Corp. Tax
12.5% Standard Case I/II
25% Case III IV V
Dividend Income
Franked Investment Income FII
from Irish Resident Co exempt :no_entry:
Foreign Dividends 25%
Lower rate of 12.5% if company from EU
or double taxation treaty country
Basis of Assessment
Based on
accounting year end
date
No one date ( unlike income tax)
Accounting period longer than 12 months
If company has 16 month period ended 1/6/17 to 30/09/18
then first 12 months to 31 May 2018-
1st tax period
01/06/18-30/09/18-
2nd tax period
12 + remainder if accounting period >12
Accounting period Shorter than 12 Months
Do multiple tax returns in same year
Not beneficial for company