ACC40930 Aviation Tax

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

Student Effort Type	Hours
Specified Learning Activities	60
Autonomous Student Learning	60
Lectures	30
Total	150

Not applicable to this module.

Not applicable to this module.
 

Assessment Strategy  

Description	Timing		Component Scale		% of Final Grade
Continuous Assessment: Team Assignment Research-led teaching Team Report, Team Presentation and Individual Reflection Please see ‘Team Work Guidance for Students’ provided.	Throughout the Trimester	n/a	Standard conversion grade scale 40%	No	50
Journal: Learning Journal This is an individual assignment, encompassing all six topics within the module and material covered by our guest lecturers. Please see ‘Learning Journal Guidance’ provided.	Throughout the Trimester	n/a	Standard conversion grade scale 40%	Yes	50

 

Remediation Type	Remediation Timing
In-Module Resit	Prior to relevant Programme Exam Board

• Feedback individually to students, post-assessment
• Group/class feedback, post-assessment

Not yet recorded.

Students will be referred to articles they are required to read throughout the course. These will either be posted on Brightspace or available in the library

Other texts

Patrick Mulcahy, Irish Taxation Law and Practice 2021-22 (Irish Taxation Institute)

Simon James and Christopher Nobes, The Economics of Taxation (Prentice Hall)

Andy Lymer and Lynne Oats, Taxation: Policy and Practice (Fiscal Publications)

Angharad Miller and Lynne Oats, Principles of International Taxation (Bloomsbury)

Vitaly S. Guzhva, Aircraft Leasing and Financing: Tools for Success in International Aircraft Acquisition and Management (Elsevier) – Chapter 13

Ronald Scheinberg, The Commercial Aircraft Finance Handbook (Routledge) – Parts 2 and 14

Rob Murphy, Aircraft Financing (Bloomsbury) – 4th Edition, Chapter 7



The above texts are available in the Campus Book Shop and in the Library.
• Available as an eBook.

In addition to the above, students are recommended to read current articles and
periodicals during the year, in particular:

Financial Times
Irish Tax Review
Accountancy Ireland
Business and Finance
British Tax Review
Fiscal Studies

These journals are available in the UCD library.

Most Sunday newspapers have a regular business/taxation advice section.

TAXFIND (Access Sponsored by KPMG)
TaxFind contains a comprehensive collection of tax related legislation, commentary, case law, seminars and Revenue documentation.

TaxFind login details
http://www.taxfind.ie/account/logIn
Username: 60680
Password: ucdtaxfind


Useful Websites for your research:
www.taxireland.ie
www.revenue.ie
www.irlgov.ie/finance
www.onbusiness.ie
www.esri.ie
www.cso.ie
www.publicpolicy.ie

Autumn
Lecture	Offering 1	Week(s) - 0, 1, 2, 4, 5	Tues 08:30 - 10:20
Lecture	Offering 1	Week(s) - 0, 1, 2, 4, 5	Tues 11:00 - 12:50
Autumn