Module
Advanced Direct Tax: International
Advanced Direct Tax: International
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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- 01The international tax map
- 02Source taxation and residence taxation
- 03Worldwide and territorial systems
- 04Citizenship-based taxation and the United States
- 05The remittance basis model
- 06Juridical and economic double taxation
- 07Capital-export and capital-import neutrality
- 08Ireland's corporation tax architecture
- 09Irish policy for inward investment
- 10Substance, functions and value creation
- 11EU influence on Irish direct tax
- 12OECD influence on Irish tax policy
- 13From BEPS 1.0 to implementation
- 14Pillar One: Amount A and Amount B
- 15Pillar Two: the global minimum tax
- 16Monitoring United Kingdom developments
- 17Monitoring United States developments
- 18Governance for international tax advice
- 19Why double taxation agreements exist
- 20Domestic law before treaty relief
- 21Legal standing of Ireland's tax treaties
- 22Treaty interpretation in practice
- 23The OECD Model Tax Convention
- 24Using the OECD Commentary carefully
- 25The Vienna Convention approach
- 26Ireland's Multilateral Instrument
- 27The principal purpose test
- 28Treaty entitlement and beneficial ownership
- 29Individual residence under Article 4
- 30Individual tie-breaker tests
- 31Employment income under Article 15
- 32Directors' fees and Article 16
- 33Pensions and government service
- 34Students, artistes and sportspersons
- 35Capital gains treaty allocation
- 36Other income and residual articles
- 37Business profits and permanent establishment
- 38The fixed-place permanent establishment
- 39The dependent-agent permanent establishment
- 40Preparatory or auxiliary activities
- 41Construction and project permanent establishments
- 42Attributing profits to a permanent establishment
- 43The authorised OECD approach
- 44Branch operation in Ireland
- 45Representative office boundaries
- 46Subsidiary company boundaries
- 47International holding companies
- 48International intellectual-property companies
- 49International finance companies
- 50Controlled foreign company rules
- 51Transfer pricing and the group effective tax rate
- 52Scope of Part 35A TCA 1997
- 53Associated persons and controlled transactions
- 54The arm's-length principle
- 55Accurate delineation of the transaction
- 56Functional analysis: functions, assets and risks
- 57Comparability analysis
- 58The comparable uncontrolled price method
- 59The resale price method
- 60The cost-plus method
- 61The transactional net margin method
- 62The transactional profit-split method
- 63Intangibles and DEMPE
- 64Intra-group services and benefit tests
- 65Intra-group loans and debt capacity
- 66Guarantees, cash pools and treasury
- 67Business restructurings
- 68Transfer pricing and permanent establishments
- 69Capital transactions and market value
- 70Contemporaneous transfer-pricing documentation
- 71Master file and local file controls
- 72Revenue monitoring and intervention risk
- 73Mutual Agreement Procedure
- 74Advance Pricing Agreements and correlative relief
- 75Country-by-Country Reporting and Amount B
- 76EU law and national direct taxes
- 77The fundamental freedoms
- 78Freedom of establishment
- 79Free movement of capital
- 80Workers and services freedoms
- 81Comparability and discrimination
- 82Justifications and proportionality
- 83State aid and selective tax advantages
- 84The EU Mergers Directive
- 85The Parent-Subsidiary Directive
- 86The Interest and Royalties Directive
- 87ATAD controlled-foreign-company rules
- 88ATAD exit tax and interest limitation
- 89ATAD2 anti-hybrid rules
- 90EU tax dispute resolution
- 91DAC6 mandatory disclosure
- 92DAC8, DAC9 and automatic exchange
- 93EU non-cooperative jurisdictions and defensive measures
- 94What is a foreign employment?
- 95Irish residence and day counting
- 96Ordinary residence after arrival and departure
- 97Domicile and the remittance basis
- 98Treaty residence for mobile employees
- 99The Article 15 short-stay test
- 100Economic employer analysis
- 101Allocating employment income by workdays
- 102PAYE for duties exercised in Ireland
- 103Foreign employers and shadow payroll
- 104Short-term business visitors
- 105PAYE dispensations and evidence
- 106PAYE Exclusion Orders
- 107Outbound employees and Irish payroll
- 108Split-year residence treatment
- 109Double-tax relief for employment income
- 110EU social security and the A1 certificate
- 111Bilateral social-security agreements
- 112Special Assignee Relief Programme
- 113SARP payroll and employer reporting
- 114Foreign Earnings Deduction
- 115Transborder Workers' Relief
- 116Mobile share awards and options
- 117Temporary non-residence and disposals
- 118Redesigning a secondment proposal
- 119The inbound investment decision tree
- 120Company residence in Ireland
- 121Treaty residence and dual-resident companies
- 122Permanent-establishment threshold for inbound groups
- 123Taxing an Irish branch
- 124Taxing an Irish subsidiary
- 125Choosing branch, subsidiary or representative office
- 126Equity funding of an Irish operation
- 127Debt funding of an Irish operation
- 128Irish withholding tax on interest
- 129Irish withholding tax on royalties
- 130Dividend withholding tax
- 131Withholding exemptions and outbound-payment controls
- 132Locating intellectual property and incentives
- 133Repatriating profits from Ireland
- 134Capital distributions and liquidations
- 135Migration and corporate exit tax
- 136International M&A and Irish stamp duty
- 137Irish tax on worldwide corporate income
- 138Foreign trading income
- 139Foreign passive income
- 140Foreign interest and tax credits
- 141Foreign royalties and tax credits
- 142Foreign branch-profit computations
- 143Branch losses and foreign permanent establishments
- 144Foreign dividends under the credit method
- 145Participation exemption for foreign distributions
- 146The five-percent and twelve-month tests
- 147The 2026 geographic expansion
- 148Participation-exemption elections and records
- 149Section 626B share-disposal exemption
- 150Branch-versus-subsidiary modelling
- 151Foreign currency and timing differences
- 152Foreign losses and relief ordering
- 153Interest Limitation Rule
- 154CFC charge in an outbound group
- 155Anti-hybrid adjustments
- 156Outbound-payment defensive measures
- 157Pillar Two scope and the EUR750 million threshold
- 158GloBE income, covered taxes and top-up tax
- 1592026 Pillar Two filing and safe-harbour controls
- 160Integrated outbound corporation-tax computation
- 161Foreign rental income for residents
- 162Foreign property and the remittance basis
- 163Rental deductions, currencies and records
- 164Treaty credit for foreign rental tax
- 165Capital gains on foreign property
- 166Foreign property where no treaty applies
- 167Property trading, development or investment
- 168Non-residents disposing of Irish property
- 169IREFs and fund structures holding Irish property
- 170Foreign-property planning and return controls
- 171Purpose of the transfer-of-assets-abroad code
- 172The power-to-enjoy route
- 173The benefits-received route
- 174Persons abroad and associated operations
- 175Motive exemptions and commercial evidence
- 176EU-law limits on anti-avoidance rules
- 177Computing the charge and double-tax relief
- 178Transfer-of-assets-abroad scenario workflow
- 179Non-resident close companies and section 590
- 180Non-resident trusts and attributed gains
- 181Offshore income gains
- 182Temporary non-residence and capital gains
- 183Market value, transfer pricing and the GAAR
- 184Treaty principal-purpose testing in wealth plans
- 185DAC6, disclosure and professional ethics
- 186Integrated international wealth review
- 187Classifying an offshore fund
- 188Material interests and net asset value
- 189Good jurisdictions for offshore-fund purposes
- 190Regulated and unregulated offshore funds
- 191Equivalent funds and gross-roll-up treatment
- 192The 38-percent individual rate from 2026
- 193The eight-year deemed disposal
- 194Personal portfolio investment undertakings
- 195Company investors in offshore funds
- 196Offshore-fund administration and decision tree
- 197The 2026 international-tax status register
- 198DAC8 reporting and the 2027 exchange cycle
- 199Pillar Two transitions affecting 2027 work
- 200Budget 2027 and Finance Act 2026 recheck protocol
- 201Congratulations on completing the module