Module
Professional Advice
Professional Advice
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 role and responsibility of a tax adviser
- 02Defining the client's commercial objective
- 03Accepting instructions and identifying the decision-maker
- 04Building a complete fact pattern
- 05Creating the transaction chronology
- 06Mapping parties, entities and beneficial owners
- 07Issue spotting across every tax head
- 08Separating facts, assumptions and unknowns
- 09Setting materiality and proportionality
- 10Using the hierarchy of tax authority
- 11Reading current consolidated legislation
- 12Researching case law and precedent
- 13Using Revenue guidance with appropriate weight
- 14Seeking opinions, confirmations and specialist input
- 15Preparing transparent calculations
- 16Comparing technically valid alternatives
- 17Writing clear, reasoned and qualified advice
- 18Project-managing implementation and closing review
- 19Tax policy, public confidence and the tax adviser's role
- 20The five fundamental professional principles
- 21Integrity and truthful communications
- 22Objectivity, independence and undue influence
- 23Professional competence and due care
- 24Confidentiality and permitted disclosure
- 25Professional behaviour and personal tax compliance
- 26Client acceptance and professional clearance
- 27Tax advisers as AML designated persons
- 28The practice-wide AML risk assessment
- 29Customer due diligence for individuals
- 30CDD for companies, trusts and beneficial owners
- 31PEPs, sanctions and enhanced due diligence
- 32Source of funds and source of wealth
- 33Ongoing monitoring and unusual transactions
- 34Suspicious transaction reports and no tipping off
- 35AML records, controls and staff training
- 36The EU AML package applying from July 2027
- 37Engagement letters and scope control
- 38Client and adviser responsibilities
- 39Fees, estimates and transparent billing
- 40Conflicts of interest and effective safeguards
- 41Client money, documents and working papers
- 42Professional indemnity and business continuity
- 43GDPR roles, lawful basis and data minimisation
- 44Secure digital advice, cloud tools and human review of AI
- 45Tax planning, mitigation, avoidance and evasion
- 46Legality, ethics and the spirit of the law
- 47Identifying a tax advantage
- 48Viewing a composite transaction as a whole
- 49The legislative response after McGrath v McDermott
- 50Section 811C: the modern GAAR architecture
- 51Testing whether a tax avoidance transaction exists
- 52Primary purpose and main-purpose tests
- 53Objective indicators in the contemporaneous evidence
- 54Form, substance and the transaction's results
- 55Misuse or abuse of statutory provisions
- 56Bona fide commercial purposes and artificial steps
- 57Revenue's GAAR opinion and taxpayer representations
- 58Withdrawing the tax advantage and compensating adjustments
- 59GAAR time limits and record preservation
- 60The tax avoidance surcharge
- 61Protective notifications under section 811D
- 62Qualifying avoidance disclosures
- 63Irish and United Kingdom judicial approaches
- 64O'Flynn, Bookfinders and a disciplined case-law file
- 65The domestic Mandatory Disclosure Regime
- 66The disclosable-transaction test
- 67Obligations of a promoter
- 68Obligations of a marketer
- 69Obligations of a user
- 70Domestic hallmarks and specified descriptions
- 71Excluded transactions and informed-observer tests
- 72Domestic MDR timing, forms and transaction numbers
- 73User returns, records and implementation controls
- 74Domestic MDR penalties and governance
- 75DAC6 and reportable cross-border arrangements
- 76DAC6 intermediaries and relevant taxpayers
- 77DAC6 hallmarks and the main-benefit test
- 78DAC6 reporting triggers and the 30-day clock
- 79Legal professional privilege and reporting transfer
- 80DAC6 filing, reference numbers and records
- 81Section 817 schemes avoiding Schedule F
- 82Company purchases of own shares under sections 176 to 186
- 83Depreciatory transactions and dividend stripping
- 84Recovery of company CGT from shareholders under section 614
- 85The taxpayer's return and the agent's responsibility
- 86Self-correction before a compliance intervention
- 87Revenue's three-level Compliance Intervention Framework
- 88Level 1 self-correction without notification
- 89Level 1 assurance checks
- 90Level 2 risk reviews
- 91Level 2 profile interviews
- 92Level 2 Revenue audits
- 93Level 3 investigations
- 94Defining the scope, tax heads and periods
- 95Reading the intervention notice and protecting deadlines
- 96Assembling books, records and reconciliations
- 97Electronic records, data extracts and secure transfer
- 98Preparing the opening meeting and client narrative
- 99Sampling, testing and reconstructing liabilities
- 100Careless, deliberate and deliberate-concealment defaults
- 101Unprompted qualifying disclosures
- 102Prompted qualifying disclosures
- 103Disclosure content, payment and declaration
- 104Cooperation and the penalty matrix
- 105Interest, penalties and surcharge calculations
- 106Publication and prosecution risk
- 107Settlement offers and inability-to-pay cases
- 108Closing letters, reservations and implementation
- 109Appealable decisions versus complaints
- 110The 30-day Notice of Appeal and late appeals
- 111Statements of Case, evidence, hearings and determinations
- 112Other tax appeals and Revenue complaint or review routes
- 113Defining succession objectives and family constraints
- 114Building the family asset and ownership map
- 115Wills, intestacy and estate administration
- 116Lifetime transfer versus inheritance
- 117CAT thresholds, aggregation and filing
- 118Agricultural relief and active-farmer evidence
- 119Business relief and six-year clawback monitoring
- 120Valuing family-company shares
- 121Retirement relief in an intergenerational transfer
- 122Revised Entrepreneur Relief in a family plan
- 123Pensions and the Standard Fund Threshold
- 124Section 72 and section 73 assurance policies
- 125Trusts, control and discretionary powers
- 126Equality, control and voting structures
- 127Funding tax, debt and family liquidity
- 128A documented succession implementation plan
- 129Marriage and civil partnership
- 130Separation, divorce and property transfers
- 131Cohabitants and the absence of automatic spouse reliefs
- 132Death, bereavement and the final tax return
- 133Residence, ordinary residence and domicile
- 134Immigration to Ireland
- 135Emigration, split-year treatment and exit issues
- 136Mobile workers, treaty residence and payroll
- 137Redundancy and termination payments
- 138Retirement timing and pension choices
- 139ARFs, pension drawdown and benefit crystallisation
- 140Moving or transferring the family home
- 141Gifts, education and maintenance for children
- 142Vulnerable beneficiaries and supported decision-making
- 143Employment status after Karshan
- 144The integrated life-event advice letter
- 145Sole trader, partnership or company
- 146Registrations, preliminary tax and the compliance calendar
- 147Accounting dates, records and cash-flow forecasting
- 148SURE and start-up income-tax relief
- 149EII and Start-up Capital Incentive funding
- 150Debt, equity and founder funding
- 151Intellectual property and legal ownership
- 152VAT, PAYE, RCT and employer obligations
- 153Director remuneration, dividends and benefits
- 154Early losses and relief ordering
- 155Founder pensions and protection policies
- 156Founder shares, options and KEEP
- 157Company-law governance and beneficial ownership
- 158The start-up recommendation and first-year action plan
- 159Organic expansion and commercial forecasts
- 160Capital expenditure and capital allowances
- 161Hiring, contractors and payroll risk
- 162The 35 percent R&D corporation-tax credit
- 163Buying assets versus buying shares
- 164Tax due diligence and red-flag reporting
- 165Tax warranties, indemnities and disclosure letters
- 166Acquisition finance and the Interest Limitation Rule
- 167Groups, losses and payment arrangements
- 168Reorganisations, reconstructions and clawbacks
- 169Intellectual property and international expansion
- 170Foreign dividends and the participation exemption
- 171Relocating employees into or out of Ireland
- 172VAT, customs and stamp duty in expansion
- 173Post-acquisition integration and compliance
- 174The expansion recommendation and implementation matrix
- 175Recognising financial distress and protecting deadlines
- 176Tax debt, engagement with Revenue and phased payments
- 177Trading losses and terminal-loss relief
- 178Fiduciary taxes, creditor priorities and personal exposure
- 179SCARP, examinership and restructuring options
- 180Liquidation, cessation and distributions
- 181Debt releases and insolvency tax consequences
- 182VAT, payroll and RCT on cessation
- 183Company-law filings, directors and specialist legal input
- 184The business-failure advice and controlled exit plan
- 185Sale objectives, readiness and transaction timetable
- 186Valuation, price allocation and tax modelling
- 187Asset sale versus share sale
- 188Vendor tax due diligence and the data room
- 189Pre-sale restructuring and balance-sheet clean-up
- 190Revised Entrepreneur Relief on a 2026 disposal
- 191Retirement relief and the post-2025 rules
- 192Section 626B for a corporate shareholder
- 193Cash, deferred consideration and earn-outs
- 194Warranties, indemnities and tax covenants
- 195Completion filings, payments and relief claims
- 196Post-sale investment, pensions and estate planning
- 197The 2026 professional-advice status register
- 198Confirmed 2027 AML and pension changes
- 199Budget 2027 and Finance Act 2026 recheck protocol
- 200Final integrated Professional Advice case
- 201Congratulations on completing the module