Links from Section 811A | ||
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Act | Linked to | Context |
Capital Acquisitions Tax Consolidation Act, 2003 |
(ii) section 46A of the Capital Acquisitions Tax Consolidation Act 2003, |
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Stamp Duty Consolidation Act, 1999 |
(iii)section 8 of the Stamp Duties Consolidation Act 1999, or |
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Stamp Duty Consolidation Act, 1999 |
(iii)section 8 of the Stamp Duties Consolidation Act 1999, or |
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Taxes Consolidation Act, 1997 |
(i) where no appeal is made under section 811(7) against any matter or matters specified or described in the notice of that opinion, 31 days after the date of the notice of that opinion, or |
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Taxes Consolidation Act, 1997 |
(ii) the date on which all appeals made under section 811(7) against any such matter or matters have been finally determined and none of the appeals has been so determined by an order directing that the opinion of the Revenue Commissioners to the effect that the transaction is a tax avoidance transaction is void. |
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Taxes Consolidation Act, 1997 |
(c) This section shall be construed together with section 811 and shall have effect notwithstanding any of the provisions of section 811. |
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Taxes Consolidation Act, 1997 |
(c) This section shall be construed together with section 811 and shall have effect notwithstanding any of the provisions of section 811. |
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Taxes Consolidation Act, 1997 |
(1A) Without prejudice to the generality of any provision of this section or section 811,
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Taxes Consolidation Act, 1997 |
at any time in connection with this section or section 811. |
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Taxes Consolidation Act, 1997 |
but this subsection shall not be construed as preventing an officer of the Revenue Commissioners from making any enquiry at any time in connection with this section or section 811. |
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Taxes Consolidation Act, 1997 |
(2) Where, in accordance with adjustments made or acts done by the Revenue Commissioners under section 811(5), on foot of their opinion (as amended, or added to, on appeal where relevant) that a transaction is a tax avoidance transaction having become final and conclusive, an amount of tax is payable by a person that would not have been payable if the Revenue Commissioners had not formed the opinion concerned, then, subject to subsection (3)— |
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Taxes Consolidation Act, 1997 |
(a) the person shall be liable to pay an amount (in this section referred to as the “surcharge”) equal to
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Taxes Consolidation Act, 1997 |
(b) for the purposes of liability to interest under the Acts on tax due and payable, the amount of tax, or parts of that amount, shall be deemed to be due and payable on the day or, as respects parts of that amount, days specified in the notice of opinion (as amended, or added to, on appeal where relevant) in accordance with section 811(6)(a)(iii) construed together with subsection (4)(a) of this section, |
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Taxes Consolidation Act, 1997 |
(2A)(a) In this subsection “qualifying avoidance disclosure” means a disclosure that the Revenue Commissioners are satisfied is a disclosure of complete information in relation to, and full particulars of, a transaction that is a tax avoidance transaction or that, had the Revenue Commissioners formed the opinion that the transaction was a tax avoidance transaction, would occasion a liability to tax pursuant to section 811, made in writing to the Revenue Commissioners and signed by or on behalf of that person and which is accompanied by— |
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Taxes Consolidation Act, 1997 |
(I) the whole of the transaction is undertaken or arranged before 2 February 2006, and would give rise to, or would but for section 811 give rise to, a reduction, avoidance, or deferral of any charge or assessment to tax, or part thereof, and |
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Taxes Consolidation Act, 1997 |
(I) the whole of the transaction is undertaken or arranged before 2 February 2006, and would give rise to, or would but for section 811 give rise to, a refund or a payment of an amount, or of an increase in an amount of tax, or part thereof, refundable or otherwise payable to a person, and |
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Taxes Consolidation Act, 1997 |
(II) that amount or increase in the amount would, but for section 811, become first so refundable or otherwise payable to the person on a date on or after 2 February 2006, |
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Taxes Consolidation Act, 1997 |
(b) Where the grounds of an appeal in relation to tax consequences refer to such a date or dates as are mentioned in paragraph (a), subsection (7) of section 811 shall apply, in that respect, as if the following paragraph were substituted for paragraph (c) of that subsection: |
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Taxes Consolidation Act, 1997 |
“(c) the tax consequences specified or described in the notice of opinion, or such part of those consequences as shall be specified or described by the appellant in the notice of appeal, would not be just and reasonable to ensure that tax is deemed to be payable on a date or dates in accordance with subsection (4)(a) of section 811A,” |
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Taxes Consolidation Act, 1997 |
and the grounds of appeal referred to in section 811(8)(a) shall be construed accordingly. |
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Taxes Consolidation Act, 1997 |
(c) Where the Revenue Commissioners form the opinion that a transaction is a tax avoidance transaction and believe that a protective notification in relation to the transaction has not been delivered by a person in accordance with subsection (6)(a) by the relevant date (within the meaning of subsection (3)(c)) then, in giving notice under section 811(6)(a) to the person of their opinion in relation to the transaction, they shall give notice that they believe that a protective notification has not been so delivered by the person and section 811 shall be construed, subject to any necessary modifications, as if— |
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Taxes Consolidation Act, 1997 |
(c) Where the Revenue Commissioners form the opinion that a transaction is a tax avoidance transaction and believe that a protective notification in relation to the transaction has not been delivered by a person in accordance with subsection (6)(a) by the relevant date (within the meaning of subsection (3)(c)) then, in giving notice under section 811(6)(a) to the person of their opinion in relation to the transaction, they shall give notice that they believe that a protective notification has not been so delivered by the person and section 811 shall be construed, subject to any necessary modifications, as if— |
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Taxes Consolidation Act, 1997 |
(b) as respects any transaction, the whole of which was undertaken or arranged before that date, in so far as it gives rise to, or would but for section 811 give rise to— |
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Taxes Consolidation Act, 1997 |
(ii) a refund or a payment of an amount, or of an increase in an amount of tax, or part thereof, refundable or otherwise payable
to a person where, but for section 811, that amount or increase in the amount would become first so refundable or otherwise payable to the person on or after
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Taxes Consolidation Act, 1997 |
(1A) Without prejudice to the generality of any provision of this section or section 811,
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Taxes Consolidation Act, 1997 |
(1A) Without prejudice to the generality of any provision of this section or section 811,
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Taxes Consolidation Act, 1997 |
(iv) |
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Taxes Consolidation Act, 1997 |
(1A) Without prejudice to the generality of any provision of this section or section 811,
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Value-Added Tax Consolidation Act 2010 |
(i)section 81 of the Value-Added Tax Consolidation Act 2010, |
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Value-Added Tax Consolidation Act 2010 |
(i)section 81 of the Value-Added Tax Consolidation Act 2010, |
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Links to Section 811A (from within TaxSource Total) | ||
Act | Linked from | Context |
Taxes Consolidation Act, 1997 |
(1)(a) |
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Taxes Consolidation Act, 1997 |
(c) For the purposes of this section and section 811A, all appeals made under section 811(7) by, or on behalf of, a person against any matter or matters specified or described in the notice of opinion of the Revenue Commissioners that a transaction is a tax avoidance transaction, if they have not otherwise been so determined, shall be deemed to have been finally determined when— |
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Taxes Consolidation Act, 1997 |
(3) Where a person provides the Revenue Commissioners with specified information relating to a disclosable transaction, the provision
of that information shall not be regarded as being, or being equivalent to, the delivery of a protective notification by that
person in relation to the transaction for the purposes of section
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Taxes Consolidation Act, 1997 |
(b) taking any action, at any time in connection with
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Taxes Consolidation Act, 1997 |
(3) Nothing in this section affects the operation of section 804(3),
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Taxes Consolidation Act, 1997 |
(4) Nothing in this section affects the operation of
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Taxes Consolidation Act, 1997 |
(9) Nothing in this section affects the operation of
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