Revenue issued a series of technical eBriefs concerning capital gains tax, exempt woodlands and VAT. Special care is needed too with some capital allowances falling defunct after the tax life of the building has expired.

The eBriefs include –

Reconstruction relief and capital gains tax group relief

This eBrief deals with the interaction of these reliefs and warns of possible challenges under section 811 or section 811C TCA 1997.

Revenue has also published a manual setting out their views on the reliefs and how the reliefs are being used as part of a scheme to avoid capital gains tax.

Exempt woodlands income and the High Income Earners Restriction

eBrief No. 80/15 addresses individuals who are not carrying on a forestry trade, and who may be using generally accepted accounting principles to spread the woodland income over a number of years. Exempt woodlands income is a specified relief for the purposes of the High Income Earners Restriction (“HIER”) per Part 15, Chapter 2A TCA 1997.

Unused capital allowances

Revenue’s eBrief No 81/15 is a reminder of the termination of certain carry forward of capital allowances. Further information on the schemes, reliefs and restrictions is available in the Revenue Tax and Duty Manual Part 10.

VAT – Portfolio Management Services

This eBrief advises that the Revenue VAT Manual has been updated to set out the revised VAT treatment applying to portfolio management services following the decision of the Court of Justice of the European Union (CJEU) in Deutsche Bank AG.

Per the eBrief the CJEU (Case C-44/11) held that discretionary portfolio management services such as those provided by Deutsche Bank should be treated as a single service and subject to VAT. Prior to the decision of the CJEU, Revenue understood that portfolio management services were comprised of several separate elements.

You can read the above mentioned eBriefs from here.