Irish Tax Review

Rustom Dalal and Kevin Norton outline how businesses should understand their AI value-chain to assess the impact on cost allocation and profit attribution.

Lee Squires considers the Court of Appeal decision in Hanrahan v Revenue Commissioners on the general anti-avoidance rule (GAAR) in s811 TCA 1997 and its potential implications for Revenue’s future application of the GAAR.

Harry Harrison, Paul McKenna and Sarah Bradley outline recent developments relating to Pillar Two, covering Finance Act 2024, Tax and Duty Manual updates and future OECD guidance, as well as Pillar Two points to consider for 2025.

Robert Dever, Gerry Beausang and Brídín Redmond explain what an earn-out is, the structuring issues to be considered, and sellers’ rights and obligations during the earn-out period, in the first article of a two-part series. Part 2 of this article was published in the Irish Tax Review, Issue 1 2025.