The tax implications for Nicola on the transfer of 100% of the shares in BFL to Ashley by way of a gift: Irish Taxation Homework, DBS, Ireland

REQUIREMENTS

In preparation for the follow up meeting with Nicola, your manager has asked that you prepare a file note to address the following matters:

(1) The tax implications for Nicola on the transfer of 100% of the shares in BFL to Ashley by way of a gift.

(2) |The tax implications for Ashley on the transfer of 100% of the shares in BFL to her by way of a gift.

(3) The tax implications if 100% of the shares in BFL are transferred to Ashley on Nicola’s death. In your answer, quantify any potential tax savings that could be achieved. You should assume that the current market value of BFL applies.

(4) Tax advice in relation to the proposed future transfer of a site by Nicola to Harry. Assume that current land values, tax rates and reliefs apply at the time of the transfer. (You do not need to consider any VAT implications in your answer).

(5) Tax advice in relation to BFL’s upcoming risk review.

(6) Tax reconciliation for the year ended 31 December 2023 in accordance with FRS 102.

The file note should include, where relevant:

° Consideration of capital gains tax, capital acquisitions tax, stamp duty, corporation tax and VAT, where appropriate.

° Details and calculations of the applicable taxes due, if any, before any available relief is applied.

° Description of any tax relief(s) that may be available and the conditions which apply in order to claim the tax relief(s).

° Where more than one relief is available in relation to a particular liability, you should describe both, consider whether the conditions for each are met and make a recommendation as to which relief to claim.

° Revised calculations of the tax payable where a particular relief is available.

° An outline of any clawback provisions which may apply.

° An outline of the filing and tax payment due dates, as applicable.