Mergers and reorganisations can result in significant capital gains tax, corporation tax, stamp duty, VAT and capital acquisitions tax charges. We fully acknowledge that while tax is not the driving force of such deals, given the potential exposure, the tax analysis often forms an integral part of the process. We advise on the tax implications associated with these structures and ensure all relevant tax reliefs are available while ensuring that the commercial outcome desired by the client is brought about. We also work closely with the appointed legal team to ensure the commercial and structuring objectives are appropriately drafted.  In advance of the transaction, we can also carry out vendor or buyer tax diligence reviews of the target company or group. The areas that we, in Purcell McQuillan, can assist in include the following:

• Reorganising trades within a group of companies.
• The introduction of new investors, including the admission of children or executives to the company.
• Merging two separate groups of companies or demerging a group of companies into two or more groups, including cross-border mergers/demergers,
• Management buy-outs
• Acquisition and vendor due diligence reviews identifying material tax exposures and making recommendations.
• Advising on tax efficient remuneration for departing executives / employees of the target company.
• The acquisition of another company or part of another company in exchange for shares.

We provide our clients with a comprehensive Value Added Tax (VAT) advisory service.  We advise on the VAT implications of specific transactions, including inter alia financial transactions, VAT on property, international transactions and services.

We have considerable experience in assisting clients prior to and during VAT audits, and in any subsequent negotiations with the Revenue. We also conduct reviews of clients’ VAT affairs to identify any opportunities to reduce ongoing VAT costs and to identify potential VAT liabilities.

We also provide a VAT compliance service including the preparation and submission of VAT returns and can arrange VAT registration for clients both in Ireland and abroad, as necessary.

A highly skilled workforce, a stable business environment and a long-term commitment to a 12.5% corporation tax rate has helped Ireland become a key strategic location for foreign direct investment. We advise companies and individuals on the tax issues associated with their investment in or relocation to Ireland. This covers a broad range of areas which may include:

• The Intellectual Property tax regime.
• The 12.5% tax rate on trading activities.
• Corporate tax residence including analysis of whether an Irish permanent establishment exists.
• The remittance basis of tax for non-domiciled Irish individuals.
• The taxation of cross-border employees and assignments to Ireland.
• Transfer pricing rules.
• The application of withholding taxes on the repatriation of profits via dividends, royalties, interest and capital distributions.

Our compliance team provide a professional and personalised service specific to your business needs.  We work to identify opportunities within the business which can promote improved decision making and to add value by reducing the administrative burden of preparing accounts and filing returns with Revenue and the Companies Registration Office.  This in turn allows our clients to focus their time on growing their business.

The services we offer include:

• Audit exempt financial statements
• Management accounts
• Outsourced bookkeeping services
• Payroll services
• Company secretarial compliance
• Comprehensive service for contractors

Trading through a company has many benefits for business owners. However, one of the downsides is the increased tax compliance obligations. Companies can have filing obligations under multiple tax heads such as:

• Corporation tax
• Value added tax (VAT)
• VIES & Intrastat
• Payroll taxes
• Relevant contracts tax (RCT)
• Dividend withholding tax (DWT)

The filing of timely and accurate tax returns with the Irish Revenue Commissioners is key to efficiently running a company. From, single entity companies to large corporate groups, we apply a thorough approach to our clients’ corporate tax compliance responsibilities ensuring true and full returns are completed and all items requiring disclosure are accurately represented. Ultimately our approach gives piece of mind to the board of directors on their compliance obligations and helps reduce the likelihood of Revenue interventions.

We recognise the diversity of taxation advice required by businesses and have the expertise to provide the comprehensive range of advice needed. Through developing and maintaining a sound relationship with business owners, we anticipate their taxation needs and develop solutions directly relevant to their situation.

Examples of our services in this area include:

• Advising on compliance requirements (preparation of accounts, income tax, corporation tax, VAT etc)
• Extracting profits from the business in a tax efficient manner
• Managing close company surcharge liabilities
• Structuring pension arrangements
• Advising on other relevant matters such as relevant contracts tax (RCT or sub-contractor’s tax), VAT, PAYE/PRSI
• Providing advice and assistance in relation to Revenue Audits and enquiries
• Implementing appropriate shareholding structures
• Passing on the business to the next generation
• Sale of the business
• Executive payroll services