Module
Advanced Direct Tax: Domestic
Advanced Direct Tax: Domestic
Educational material, not professional, tax or legal advice. Figures reflect Irish law as understood when written — check Revenue.ie or a qualified adviser before acting. Not affiliated with or endorsed by any professional body.
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- 01Understand why companies operate within group structures and the special tax rules governing losses, asset transfers and payments within groups
- 02Domestic group structure map and separate-entity control
- 03Intercompany payments and Finance Act 2025 section 41
- 04Group evidence file, governance and tax-calendar control
- 05Define a "capital gains group"
- 06Explain and apply the group relief available for capital gains
- 07Illustrate how the relief applies to disposals outside the group
- 08Apply any restrictions on relief where a company joins a group with existing capital losses
- 09Describe and apply the implications of a company ceasing to be a member of the group
- 10Calculate the capital gains group relief available
- 11Section 616 capital gains group percentage map
- 12Section 617 no-gain/no-loss transfer working
- 13Section 619 outside-group disposal base cost
- 14Sections 623 and 624 degrouping charge and merger exception
- 15Section 626B participation exemption inside a group
- 16Exit tax, development land and group anti-avoidance
- 17Define a group/consortium for corporation tax purposes
- 18Identify and apply any group reliefs available for corporation tax purposes
- 19Explain the interaction of group relief with other reliefs
- 20Describe and apply the reliefs in various situations including:
- 21Corresponding accounting periods
- 22Companies joining or leaving a group
- 23Restrictions on group relief
- 2475% corporation tax group and effective entitlement tests
- 25Consortium relief ownership and five-member control
- 26Corresponding accounting period apportionment
- 27Current-period trading losses and excess charges
- 28Group relief on a value basis for chargeable gains
- 29Claims, consents, CT1 disclosure and time limits
- 30Interest Limitation Rule interaction with group relief
- 31Group payments, Pillar Two and tax accounting entries
- 32Define "associated companies"
- 33Explain how associated companies relief operates
- 34Apply the restrictions on associated companies relief
- 35Calculate the associated company relief available
- 36Section 79 90% association test
- 37Section 79 alternative merger conditions
- 38Two-year clawback and change-of-control monitor
- 39Leases, eStamping and evidence limits of group relief
- 40Compare the reliefs available to groups under each tax head
- 41Define what constitutes a group under each tax head
- 42Understand the terms used and adjustments necessary when preparing group accounts
- 43Describe some of the key concepts relating to group re-organisations
- 4475%, 51% and 90% group tests compared
- 45Loss, asset and stamp relief transaction matrix
- 46Group accounts consolidation terminology for tax advisers
- 47Reorganisation scoping and multi-tax clearance plan
- 48Apply the tax, legal and accounting implications which arise for a company on raising capital through various means including through the Employment Investment Incentive
- 49Describe the legal process by which reduction or reorganisation of share capital takes place
- 50Describe and apply any reliefs available on reorganisations of share capital
- 51Explain and apply the taxation implications of a company buying its own shares
- 52Describe and apply any reliefs available on share buy-backs
- 53Debt, ordinary shares, preference shares and convertibles
- 54EII investor and company qualification checklist
- 55EII investment and company fundraising limits
- 56SURE and start-up capital alternatives
- 57Share premium, bonus issues and rights issues
- 58Companies Act capital reduction and Summary Approval Procedure
- 59Selective buy-back: distribution versus capital treatment
- 60Section 135 anti-avoidance and commercial-purpose evidence
- 61Describe and apply any reliefs available on the transfer of a business to a company
- 62Apply company reconstructions and amalgamations including A share for share exchange A share for undertaking two-party swap A share for undertaking three-party swap Stamp Duty relief
- 63Compare the reliefs available for reorganisations and amalgamations
- 64Outline the Irish and EU law surrounding company arrangements and reconstructions
- 65Describe how company reconstructions and amalgamations take place
- 66Describe the legal processes involved in company reconstructions and amalgamations
- 67Awareness of the legal issues surrounding reorganisations involving a sale of a company including prohibitions and exclusions to financial assistance
- 68Apply the CGT participation exemption on the disposal of shares and on certain assets related to shares
- 69Apply valuation techniques to shares in a number of different case studies
- 70Describe and apply the taxation of earn-outs
- 71Section 600 transfer of business to a company
- 72Sections 586 and 587 share exchanges and schemes
- 73Section 615 reconstruction transfer of assets
- 74Section 80 stamp-duty reconstruction relief
- 75Companies Act merger and division routes
- 76Financial assistance prohibition and Summary Approval Procedure
- 77Section 626B substantial-shareholding exemption
- 78Revised Entrepreneur Relief: EUR 1.5 million limit
- 79Retirement Relief: 2025-onward limits and deferral
- 80Earn-outs, valuations, clearances and post-sale reporting
- 81Understand why share options and share awards are used in practice and distinguish between them
- 82Outline the advantages and disadvantages for both employee and employer when share options or share awards are entered into
- 83Describe the events that occur in the life of an option: grant; exercise; forfeiture; abandonment and sale
- 84Explain the taxation of unapproved employment share options and advise on the Key Employee Engagement Programme (KEEP)
- 85Calculate any Irish income tax and CGT liability arising on an unapproved share option
- 86Describe the filing requirements for both employer and employee, and any relief available to the employer
- 87Critically compare the use of approved profit sharing schemes, restricted shares ("clogs"), forfeitable shares, convertible shares and restricted stock units as a means of rewarding employees. In relation to each, identify any relief available for the employer, describe the employer and employee filing requirements and calculate any related Irish income tax and CGT liabilities
- 88Explain the taxation of gains made where an employee disposes of shares acquired under these schemes and their employer allows them to sell the shares for more than market value
- 89Unapproved option gains through payroll from 2024
- 90KEEP availability through 1 January 2029
- 91KEEP grant, exercise, disqualification and disposal
- 92Restricted shares and clog reduction
- 93RSUs, forfeitable shares and convertible securities
- 94APSS, ESOT and SAYE comparison
- 95Form RSS1, KEEP1 and ESA reporting by 31 March
- 96Mobile employees and internationally apportioned awards
- 97Employer corporation-tax deduction and payroll funding
- 98Share valuation, cashless exercise and CGT base cost
- 99Describe an acquisition transaction in overview, identify issues relevant to transaction structuring and describe the due diligence process and other preliminary issues
- 100Evaluate the financial statements of a business identifying potential tax due diligence issues
- 101Identify and interpret the key provisions of share purchase agreements and asset purchase agreements
- 102Describe the purpose of warranties/indemnities seen in share purchase agreements and asset purchase agreements, the relevance of the disclosure letter, and the principal features of the tax deed
- 103Outline the deferred tax requirements under IFRS surrounding the acquisition of a business
- 104Contrast the taxation implications on the sale of shares to the sale of assets
- 105Contrast the implications of raising finance for a business acquisition through cash, debt or equity
- 106Awareness of how dividends out of pre-acquisition profits are treated as a repayment of capital
- 107Buyer and seller objectives: share deal versus asset deal
- 108Tax due-diligence request list and red-flag register
- 109SPA, APA, disclosure letter and tax deed
- 110Tax warranties, indemnities, covenants and limitations
- 111Completion accounts, locked box, escrow and retentions
- 112VAT transfer-of-business and property transaction controls
- 113Stamp duty, section 980 clearance and completion funds
- 114Acquisition debt, section 247 and section 249
- 115Interest Limitation Rule and financing capacity
- 116IFRS 3, IAS 12 and FRS 102 deferred tax
- 117Pre-acquisition dividends and capital treatment
- 118Post-completion CT1, payroll, RCT, iXBRL and record handover
- 119Understand why a receiver, examiner or liquidator may be appointed and compare when each may be appointed including the process involved
- 120Summarise the taxation implications of liquidating/winding up a company
- 121Summarise the taxation implications of the liquidation of a family company and analysis of the availability of retirement relief
- 122Apply how CGT applies on the appointment of a liquidator
- 123Members' and creditors' voluntary liquidation compared
- 124Receiver, examiner, process adviser and liquidator roles
- 125SCARP and Revenue debt participation
- 126Pre-liquidation distributions and capital treatment
- 127Terminal losses, cessation accounts and final returns
- 128Family-company liquidation and retirement-relief evidence
- 129Apply the Irish taxation implications for individuals and companies arising on the write off of a debt by a lender
- 130Outline the tax implications for individuals and companies acquiring debt/loan books and funds, including analysing the availability of an interest deduction and distinguishing the asset from the loan book
- 131Understand the tax implications for individuals and companies where guarantees are called into effect
- 132Trading debt release for the debtor
- 133Creditor impairment, bad-debt deduction and capital loss
- 134Connected-party debt waivers and value transfers
- 135Loan-book acquisition, interest withholding and section 247
- 136Guarantee payments, subrogation and recoverability evidence
- 137Contrast the different types of trusts and understand commercially why they may be used in practice including the special rules that apply for permanently incapacitated individuals
- 138Summarise and apply the charge to income tax, CGT and stamp duty in relation to assets settled on a trust
- 139Summarise and apply the income tax and CGT rules that apply to trustees on the taxable profits and gains arising from the trust property
- 140Calculate the taxable profits and gains of a trust
- 141Describe the distributions that may be received from a trust and explain the income tax and CAT treatment of beneficiaries of a trust
- 142Describe and identify the anti-avoidance rules that can arise
- 143A settlor of a revocable trust
- 144Trusts in favour of a settlor's children
- 145Summarise the tax implications for the settlor/beneficiaries of a capital distribution from a trust
- 146Trust classification: bare, fixed, discretionary and revocable
- 147Trust residence, source and non-resident anti-avoidance
- 148Trust income tax and 20% undistributed-income surcharge
- 149Trustee CGT at 33% and appointment events
- 150Beneficiary income credits and CAT on capital appointments
- 151Discretionary Trust Tax: 6% initial and 1% annual
- 152CRBOT registration and beneficial-owner updates
- 153Special trusts for permanently incapacitated persons
- 154Form 1, Form IT38, DTT returns and evidence file
- 155Advise on how to manage an individual's tax affairs in a tax efficient manner focusing on Employment and Investment Incentive (EII) and other tax incentives. Calculate the tax arising based on the advice provided
- 156Understand why family partnerships are used and advise on the issues surrounding the holding of assets through a family partnership
- 157Outline Stamp duty relief for farm consideration
- 158Compare the income tax, CGT and CAT rules which apply in the year of death
- 159Determine the residency of an estate
- 160Apply the income tax and CGT treatment of personal representatives and executors
- 161Outline the income tax treatment applicable to payments of income during the course of administration
- 162Advise individuals using common estate planning techniques on how to manage their affairs
- 163EII, KEEP and pension incentives in wealth planning
- 164Family partnership governance and beneficial ownership
- 165Farm transfers: CGT, CAT and stamp duty interaction
- 166Year-of-death income tax and personal credits
- 167Estate residence, administration income and Form 1
- 168Personal representative CGT and date-of-death values
- 169Business Relief, Agricultural Relief and CGT credit
- 170Section 72 assurance, wills and 2027 estate review
- 171Evaluate what a pension strives to achieve and compare the pension options available including managed pension schemes and self-administered schemes
- 172Compare the pre-retirement pension scheme options
- 173Evaluate the options available on retirement and the post-retirement scheme options
- 174Understand other pension tax considerations
- 175Compare the taxation of managed pension schemes to the taxation of self- administered pension schemes and other options available including investing in property
- 176Compare a self-employed individual making a pension contribution to a company making contributions for an employee's benefit
- 177Evaluate alternative retirement plans and potential solutions and identify optimal outcomes to avail of tax reliefs available
- 178Age-related pension contribution percentages
- 179EUR 115,000 earnings cap and marginal-rate relief
- 180Employer PRSA and PEPP 100% salary limit
- 181Occupational scheme, PRSA, RAC and PEPP comparison
- 182Self-administered pension property controls
- 183Retirement lump sums: EUR 200,000 and EUR 500,000 bands
- 184Approved Retirement Funds and imputed distributions
- 1852026 Standard Fund Threshold of EUR 2.2 million
- 186Enacted 2027 Standard Fund Threshold of EUR 2.4 million
- 187MyFutureFund 2026-2028 contribution structure
- 188Pension death benefits, CAT and succession evidence
- 189Outline the main provisions of the law surrounding separation and divorce and contrast a legal separation and a divorce
- 190Compare voluntary maintenance payments to those under a deed of separation or a maintenance pending suit order
- 191Evaluate a set of circumstances and apply the law surrounding divorces in Ireland to determine whether the facts presented represent a legally enforceable divorce settlement or a voluntary settlement
- 192Analyse, compare and advise on the various tax issues associated with separation and divorce in the year of separation/divorce and thereafter including the impact on the family home, the family business and succession planning
- 193Communicate the tax implications of foreign divorces and remarriage
- 194Contrast the taxation of married persons with civil partners and cohabitants
- 195Year of permanent separation and assessment basis
- 196Legally enforceable versus voluntary maintenance
- 197Child maintenance and payer-recipient treatment
- 198Court-ordered asset transfers and the family home
- 199Family business, pensions and succession on divorce
- 200Foreign divorce recognition and qualified cohabitants
- 201Congratulations on completing the module