Learning Outcomes:
By the end of this module, students should be able to:
• Identify whether any of the taxes covered in the module applies in a particular instance;
• Identify whether any reliefs apply to mitigate any tax liability arising for any of these taxes;
• Identify whether a proposed transaction should be modified to avail of any particular relief;
• Compute any tax arising;
• Identify the parties liable to pay any tax arising;
• Identify the due dates for the paying of any tax arising and the filing of any returns
Students should also be able to:
• Identify whether an individual is resident, ordinarily resident or domiciled and outline their exposure to income tax;
• Identify and compute the tax liability of individuals who receive shares or share option, termination payments or lump sums payable on retirement;
• Identify and compute the tax liability of company directors;
• Identify whether an corporate body is resident and outline its exposure to corporation tax or income tax;
• Outline and/or compute the relief available for intellectual property and research and development;
• Identify whether a company is a close company and it tax consequences;
• Identify transactions which fall within the close company rules and/or compute any corporation tax liability arising;
• Compute the close company surcharge and/or professional services company surcharge;
• Identify with a group exists for corporation tax purposes and outline any group relief available;
• Compute any group relief available on the transfer of assets between group companies;
• Compute any group relief available on the surrender of losses or R&D tax credits between group companies.
Indicative Module Content:
Topic 1: Income Tax Introduction; recapitulation of undergraduate/CAP 1 material; residence, ordinary residence and domicile; taxation of married and separated couples; taxation of interest from EU financial institutions.
Topic 2: Income Tax Death of assessable or non-assessable spouse; split year treatment; SARP relief; FED relief; termination payments.
Topic 3: Income Tax Share awards and share options; taxation of company directors; EIIS relief; rent paid to non-resident landlords.
Topic 4: Corporation Tax Introduction; recapitulation of undergraduate/CAP 1 material; corporate residence taxation of resident and non-resident companies; payment of corporation tax.
Topic 5: Corporation Tax Close companies: definitions; existence of a close company; implications of close company rules; s83 investment companies.
Topic 6: Corporation Tax Close company surcharge; surcharge on professional service companies.
Topic 7: Corporation Tax Taxation of intellectual property; capital allowances on intellectual property; the research and development tax credit: definitions, availability and use of relief.
Topic 8: Corporation Tax Research and devleopment tax credit: computation of relief; computation of refund; surrender of credits to employees.
Topic 9: Corporation Tax Taxation of foreign income: foreign dividends and s21B, foreign rental income, and other foreign income; corporation tax on chargeable gains; participation exemption; international taxation and double taxation relief.
Topic 10: Corporation Tax Losses: introduction and recapitulation of undergraduate/CAP 1 material; use of trading losses and charges
Topic 11: Corporation Tax Losses on the transfer or cessation of a trade; Capital gains groups
Topic 12: Corporation Tax Corporation tax groups and surrender of losses; surrender of R&D tax credits within a group.