Learning Outcomes:
Learning Outcomes:
Having completed this module students will be able to:
1. Understand and critique national and international tax policies surrounding the aviation sector.
2. Understand the sources of tax law.
3. Understand and apply the rules of tax jurisdiction in Ireland.
4. Explain the trading status of aircraft leasing companies drawing upon case law and revenue rulings.
5. Understand and apply the rules of corporate residence in Ireland.
6. Explain the tax treatment of, and reliefs available for, mobile workers in Ireland.
7. Understand the Irish tax system as it applies to the aircraft leasing sector, in particular as regards capital allowances and
interest deductions
8. Explain the key international taxation issues that arise in the aircraft leasing sector, in particular permanent establishments,
withholding taxes and the impact of double taxation treaties.
9. Understand taxation issues arising from changes to the international tax regime.
Indicative Module Content:
Introduction to Module
• Introduction
• Studying taxation and its importance
Topic One – Introduction to taxation
• The nature and purpose of taxation
• History of taxation
• Taxation policy – key questions
• Assessing tax policy
Topic Two – The Irish tax system - introduction
• Nature of system and taxes charged
• Sources of tax law – role of EU and OECD
• Territorial rules – taxation based on residence and source
• Rates of tax
• The meaning of “trading” for Irish tax purposes
Topic Three – The Irish tax system – residence and source taxation
• Residence, ordinary residence and domicile for Irish tax purposes
• Corporate residence and the Double Irish
• The taxation of mobile workers
Topic Four – The Irish tax system – taxation of aircraft leasing
• Corporation tax
• VAT and stamp duty
• Capital allowances
• Interest deductions
Topic Five – International taxation and aircraft leasing
• Withholding taxes
• International double taxation
• Double taxation treaties
• Permanent establishments
Topic Six – Current and future taxation issues for aircraft leasing in Ireland and abroad
• OECD Base Erosion and Profit Shifting project part 1
• OECD Base Erosion and Profit Shifting project part 2 – pillars 1 and 2
• EU rules – Anti Tax Avoidance Directive,
• EU rules – Common Consolidated Corporate Tax Base
• EU rules – Digital taxation