Finance Act 2011 introduced significant changes to Ireland’s securitisation regime, including the welcome inclusion of commodities in the list of qualifying assets for investment. The Act also introduced changes affecting the rules on the deductibility of profit participating interest and swap payments in certain cross border structures. Andrew Quinn and William Fogarty of Maples and Calder explain the benefits.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Former IRS commissioner Danny Werfel argues that the biggest obstacle to AI adoption in tax is not technology, but trust, and introduces a practical AI risk framework to help
Howell takes a deep dive into how he led the landmark PepsiCo dispute, discusses the ATO's enforcement priorities, and emphasises KordaMentha's market ambitions
The software space was previously more fragmented, but that model is becoming more difficult to sustain as tax administration becomes increasingly digitised
While some may argue that heads should roll following KPMG Australia’s audit leak scandal, client and revenue data emphasises that tax team stability is paramount
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny