Mary Dineen

Featured in: Favicon

lexology.com Favicon

mondaq.com

Articles

CJEU Upholds The Supremacy Of Legal Professional Privilege

Nov 19, 2024 | mondaq.com | Ailish Finnerty |Orlaith Kane |David Kilty |Mary Dineen

CJEU again upholds the supremacy of legal professional privilege over national disclosure requirements of taxpayer information pursuant to DAC 6 In response to a preliminary reference from Luxembourg, the Court of Justice of the European Union (CJEU) has found that legal advice in company law matters falls directly within the scope of Article 7 of the Charter of Fundamental Rights of the European Union (the “Charter”), and a request for a lawyer to provide confidential information on these...
Highlights From Irish Finance Bill 2024

Oct 17, 2024 | mondaq.com | Ailish Finnerty |David Kilty |Orlaith Kane |Mary Dineen

The Irish Finance Bill 2024 has been published. It contains the measures announced by the Irish Minister for Finance in his Budget speech on 2 October 2024, in addition to other changes to Irish tax legislation. The Finance Bill 2024 (the "Finance Bill") has been published and completed the first Stage of the legislative process.
Highlights from Irish Finance Bill 2024

Oct 16, 2024 | lexology.com | Fintan Clancy |Ailish Finnerty |David Kilty |Orlaith Kane |Mary Dineen

The Irish Finance Bill 2024 has been published. It contains the measures announced by the Irish Minister for Finance in his Budget speech on 2 October 2024, in addition to other changes to Irish tax legislation. The Finance Bill 2024 (the “Finance Bill”) has been published and completed the first Stage of the legislative process.
Ireland Introduces A Participation Exemption For Foreign Distributions

Oct 15, 2024 | mondaq.com | Ailish Finnerty |Orlaith Kane |David Kilty |Mary Dineen

AC Arthur Cox More Arthur Cox is one of Ireland’s leading law firms. For almost 100 years, we have been at the forefront of developments in the legal profession in Ireland. Our practice encompasses all aspects of corporate and business law. The firm has offices in Dublin, Belfast, London, New York and Silicon Valley.
High Court Issues Judgment On Residence Of Delaware LLC Under US/Ireland Double Tax Treaty

Oct 10, 2024 | mondaq.com | Fintan Clancy |Mary Dineen |Ailish Finnerty |Orlaith Kane

The Irish High Court overturns the Determination of first tier Tax Appeal Commissioner to conclude that that a Delaware LLC was not "liable to tax" and therefore not "resident" within Article 4 of the US/Ireland Double Tax Treaty.Consequently, three Irish subsidiaries were not entitled to rely on Irish group loss provisions or Article 25 of the US/Ireland Double Tax Treaty.
High Court issues judgment on residence of Delaware LLC under US/Ireland Double Tax Treaty

Oct 9, 2024 | lexology.com | Fintan Clancy |Mary Dineen |Ailish Finnerty |Orlaith Kane |David Kilty

The Irish High Court overturns the Determination of first tier Tax Appeal Commissioner to conclude that that a Delaware LLC was not “liable to tax” and therefore not “resident” within Article 4 of the US/Ireland Double Tax Treaty.Consequently, three Irish subsidiaries were not entitled to rely on Irish group loss provisions or Article 25 of the US/Ireland Double Tax Treaty.
CJEU Judgment On UK CFC Rules Contrasts With Apple Judgment

Sep 30, 2024 | mondaq.com | Patrick Horan |Mary Dineen

On 19 September the Court of Justice of the European Union (CJEU) issued a judgment annulling the European Commission Decision concluding that an exemption in the UK Controlled Foreign Company ("CFC") legislation, relieving multinational groups from the full CFC charge in certain circumstances, constituted partially illegal State aid. The European Commission Decision concerned an exemption within the UK CFC rules known as the 'group financing exemption'.
The CJEU draws a line under the Apple State aid saga

Sep 12, 2024 | lexology.com | Fintan Clancy |Ailish Finnerty |David Kilty |Orlaith Kane |Richard Ryan |Patrick Horan | +1 more

The Court of Justice of the European Union (CJEU), sitting as the Grand Chamber has handed down its judgment in the Apple case. In 2016 the European Commission concluded that Ireland granted illegal State aid to two Apple group subsidiaries in two tax rulings granted in 1991 and 2007. The General Court had annulled this Decision, but the CJEU has upheld the Commission Decision in full and given final judgment on the matter with no remittance back to the General Court and no ability to appeal.