Irish Tax Institute Annual Conference

2014

Irish Tax Institute Annual Conference

Managing Tax in a Recovering Economy Thurs 10 – Sat 12 April 2014 Radisson Hotel, Galway

9 HOURS CPD

The major tax issues for advisers in practice and corporates Sponsors:

To book online please click here, email [email protected] or return the attached booking form.

Annual Conference 2014 Programme Time

Topic

Speaker(s)

Thursday 10 April 2014 20.30 – 22.00

Welcome Reception – including drinks, canapés and entertainment

Friday 11 April 2014 08.30 – 09.15

Registration

09.15 – 09.30

Opening Remarks Chairperson

Helen O’Sullivan President, Irish Tax Institute

09.30 – 10:15

1

Important Tax Decisions for Smes in an Improving Economy >> Structuring property ownership – the options and the tax implications >> Share buy-backs – when to do it, how to manage it and what to watch out for >> Carrying debt, managing it and the tax implications >> Surcharges, distributions, directors’ loans and other day to day tax issues

John Heffernan Tax Partner

10.15 – 11.00

2

Managing Businesses Out of Debt and Insolvency >> New tax technical changes – debt releases and Finance (No. 2) Act 2013 >> Land dealers – write-offs & losses >> Restrictions for limited and non-active partners >> Managing corporate insolvency >> Receivers and direct taxation – what is the current position?

Ciaran Desmond Managing Partner

Personal Insolvency – What’s Actually Happening >> What’s happening on the ground with PIPs >> How the new system is working >> Revenue engagement – real life case scenarios 11.00 – 11.30 11.30 – 12:30

Tea/Coffee 3

Succession, Pensions and Planning for the Future Business Owners – Looking After the Next Generation >> Retirement Relief – making good tax decisions under the new rules >> The mechanics of retirement planning and succession >> Use of trusts >> Family partnerships >> Shareholders’ agreements

Susan O’Connell Partner

Personal Pensions Planning for the Future >> The future landscape – DB and DC deficits >> State Pension push-out – the impact >> CAT, ARFs and the next generation >> Managing the pension levy and fund caps

Aidan McLoughlin Managing Director

Solicitors

Pensions – the Employer’s Focus >> Employer obligations >> Administering and accounting for schemes 12.30 – 13.00

Panel Discussion Incorporating Q&A Session

13.00 – 14.15

Lunch Split Sessions – Option 1 Chairperson

14.15 – 15.25 4a.

15.25 – 15.45

Andrew Gallagher Deputy President, Irish Tax Institute

Tax, Finance and Mobility for Growth and Export Tax, Structure and Finance for the Four Key Stages of Business Development >> Start-up >> Raising tax-efficient finance >> Choosing the best corporate structure >> Growth and acquisition >> Export, expansion and PE considerations >> Decline, de-merger and exit

Ronan MacNioclais Tax Partner

Exporting and Expanding – the Important Employee Tax Issues >> Mobile employees >> Secondments, assignees and PE considerations >> Exclusion orders >> Treaty impact >> Social security >> FED and SARP

Francis Farrell Tax Director

Enterprise Ireland Grants & Supports for Outbound Business

Joe Healy Manager, Policy and Government Relations Department

Colm O’Callaghan Tax Senior Manager


Time

Topic OR

Speaker(s)

Split Sessions – Option 2 Mary Honohan Vice-President, Irish Tax Institute

Chairperson 14.15 – 15.00 4b. i Your Transfer Pricing Policy in Action >> 4 years on – Revenue’s approach to TP >> Practical implementation of TP policies – real life scenarios and common risks >> BEPS: its influence on the future of TP and the impact on traditional v. digital business models >> An overseas perspective – EMEA & US trends

Karen Lynn Associate Director

15.00 – 15.45 4b. ii Managing an International Tax Function >> Tax reporting to the Board – what this involves >> Compliance and engagement with Revenue authorities >> Effectively engaging with the treasury function >> Update on BEPS and key international developments

Saibh Young Head of Tax, EMEA

15.45 – 16.10

16.10 – 16.50

Tea/Coffee

5

Chairperson

Sandra Clarke Council Member, Irish Tax Institute

Key Revenue Projects and their Impact >> Contractors – the current state of play >> The Code of Practice for Revenue Audits – a look at the changes >> New technology and software in Revenue – the impact on you and your clients >> iXBRL – what you need to do before the October 2014 deadline >> Reform of the Appeal Commissioners – what it means for tax advisers and taxpayers

Jim Kelly Tax Director

16.50 – 17.30

Panel Discussion Incorporating Q&A Session

19.30

Drinks Reception – sponsored by ITC Conference Dinner

Saturday 12 April 2014 Chairperson

David Fennell Council Member, Irish Tax Institute

10.00 – 10.40

6

A Fresh Look at VAT on Property as the Market Moves >> Pre-contract VAT enquiries and special condition 3 >> Transfer of business relief and property >> Automatic cancellation of the waiver of exemption on a sale – the potential costs >> Tenant refurbishment – issues on surrender/assignment

Donal Kennedy Director

10.40 – 11.40

7

Taxing Funds & Other Investments – Real-life Scenarios >> Understanding the client’s assets and appetite for risk >> Asset allocation and investment structures >> Recent investment trends >> Working through the tax – client scenarios >> Anticipating unexpected tax outcomes

Jane Florides Principal

Mastering the High Earners’ Restriction >> Interaction with the new legislation on double tax relief and its impact >> Full self-assessment and the challenges tax advisers must address >> Unexpected interactions with the tax code – the anomalies and the outcome for taxpayers

Laura Lynch Tax Director

11.40 – 12.15

8

12.15 – 12.25

Questions and Answers

12.25 – 12.30

Closing Remarks

K E N N E L LY Tax Advisers Limited

Laura DeVoy Investment Manager

Helen O’Sullivan President, Irish Tax Institute Conference Close


Speaker Biographies Ciaran Desmond is the Managing Partner of McGuire Desmond Solicitors. He is an FITI Chartered Tax Adviser (CTA), a Fellow of Chartered Accountants Ireland and a member of the Incorporated Law Society of Ireland. Ciaran is a Council Member of the Irish Tax Institute and is very involved in representing members’ interests through his membership of the Institute’s Tax Administration Committee and the South-West Region Branch Network. He is one of the Institute’s representatives at Main TALC. Ciaran has lectured extensively over the years and has spoken at the Irish Tax Institute’s Annual Conference and Joint Conference with Revenue. He was author of FINAK for 3 years prior to becoming a Council Member. He has been an adviser in a number of leading taxation cases in Ireland.

Karen Lynn is an Associate Director in the Transfer Pricing Team in KPMG Dublin. She has recently returned to Dublin, having spent the last three years working in the Transfer Pricing Team in KPMG London. Prior to joining KPMG London, Karen worked in a large multinational company in the pharma industry, as the in-house European Tax Manager, where she was responsible for all tax issues including the implementation of transfer pricing policies, documenting and defending transfer pricing policies in tax audits carried out by tax authorities all over Europe including Germany, France, Hungary and Russia. Karen trained in the Corporate Tax department of KPMG Dublin and is an AITI Chartered Tax Adviser (CTA) and an ACA Chartered Accountant.

Laura DeVoy has worked with Goodbody for 13 years. She progressed from a generalist analyst role to focus on financials and consumer discretionary ahead of becoming an Investment Manager. She is a member of the Asset Allocation Committee and the Equity Committee responsible for all equity recommendations within Wealth Management. Laura has lectured for many of the major universities and regularly presents on national media, including RTE and Today FM. Laura is a CFA charter holder, has a Masters in Investment and Treasury for which she received a scholarship and a degree in business studies from DCU. Laura manages a discrete number of high net worth portfolios.

Ronan MacNioclais joined PwC in 1998 and is an international tax partner heading up the M&A Tax Group of the Irish firm. He also leads the Irish Energy, Renewables and Utilities Tax Group. Ronan has extensive experience advising Irish Plcs and multi-national groups on Irish and international tax structuring including operating company/ property company structures, group financing, group reorganisations and use of entrepreneur structures. He has also advised on a wide variety of cross-border acquisitions and disposals by leading international private equity houses and sovereign wealth funds. As a tax adviser to some of Ireland’s largest energy and renewable operations Ronan has an in-depth knowledge of industry issues including carbon tax, optimisation of capital allowance claims and, using his M&A expertise, has advised acquirers and targets in this rapidly consolidating sector. Ronan is an AITI Chartered Tax Adviser (CTA) and a member of the Institute of Chartered Accountants.

Francis Farrell is a Tax Director at Contracting PLUS, prior to which he held director level positions with both Deloitte and PwC. Francis is an AITI Chartered Tax Adviser (CTA) and he advises on a broad range of both domestic and international contractors in relation to tax, social security and international mobility related issues. During his time with Deloitte and PwC, Francis lead a large number of complex tax and social security audits and investigations. He has also contributed to a number of Irish and International tax publications on both tax and social security issues.

K E N N E L LY Tax Advisers Limited

Aidan McLoughlin, BCL Solr FITI TEP AIIPM, is the Managing Director of Independent Trustee Company which specialises in the provision of pension and investment structures and related services to financial advisors and their clients. Aidan is a FITI Chartered Tax Adviser (CTA) and a Fellow of the Irish Association of Pensions Management (IIPM). He is also a member of the Law Society of Ireland, the Society for Trust and Estate Practitioners (STEP) and the Association of Pension Lawyers of Ireland (APLI). Aidan is a Council Member of the Irish Brokers Association and currently chairs both the Pensions and Communications Committees. Aidan also acts as editor of the Irish Broker magazine. Aidan was founding Chairman of the Association of Pensioner Trustees of Ireland (APTI). He is editor of the Irish Tax Institute’s publication Pensions: Revenue Law and Practice.

Jane Florides is a Principal and Co-founder of Kennelly Tax Advisers Limited, the private client tax advisory firm. Jane has specialised in the area of private client tax advice since qualifying as an AITI Chartered Tax Adviser (CTA) in 1998 (achieving first place in Ireland in her final tax exams). Jane is widely recognised as a leading expert advising High Net Worth Individuals on the taxation treatment of complex investment portfolios, offshore funds and related entities. Her other main area of expertise is tax residence and domicile. Joe Healy is Manager of the Policy and Government Relations Department and Secretary to the Board of Enterprise Ireland.

Colm O’Callaghan is a Tax Senior Manager in PwC’s Domestic International Outbound division. He joined PwC in 2003 and has worked as part of the firm’s Irish privately held corporate tax team since 2004. Colm is a member of the Institute of Chartered Accounted in Ireland and is also an AITI Chartered Tax Adviser. Colm’s experience covers a wide range of corporation tax compliance and planning, including domestic and international structuring and financing. He has extensive experience in advising listed companies, major multi-nationals and a variety of privately owned Irish companies structure into the likes of Brazil, South Africa, Kenya, Nigeria, India, Russia, Indonesia and Eastern Europe. He has also been involved in providing restructuring and recovery services to a number of clients. This has included dealing with distressed property, undertaking independent business reviews, and assisting with financial and bank restructure arrangements for some of Ireland’s largest SMEs.

John Heffernan is a tax partner in EY’s Limerick office since 1991. John is also Head of Private Client Services in Ireland. John has extensive experience in all aspects of tax. He has particular experience in advising family owned businesses and high net worth individuals on a range of tax issues. He has extensive experience of advising entrepreneurs on the tax issues facing their businesses and themselves. John also advises a number of international groups on all aspects of their tax strategies. John is an FITI Chartered Tax Adviser (CTA) and has written and lectured extensively in Ireland and abroad on a range of tax issues. Jim Kelly has over 25 years’ experience in all areas of Irish taxation having spent 10 years with the Revenue Commissioners and subsequently working as a Director of Taxation and Head of Tax Risk with Grant Thornton, Dublin. Jim is an AITI Chartered Tax Adviser (CTA) and a Council Member of the Irish Tax Institute and a member of the Institute of Certified Public Accountants in Ireland. He is also on the Dublin region of the Institute Branch Network. Donal Kennedy is a Solicitor and Director with Deloitte specialising in indirect taxation. He is a member and former chairman of the Law Society Taxation Committee, and represents The Law Society on Indirect Taxes – TALC. He has lectured and written extensively on VAT, and is author of VAT on Property published by the Irish Tax Institute.

Laura Lynch is a Tax Director with Mazars, specialising in providing advice to owner-managed businesses in the SME sector. She is an AITI Chartered Tax Adviser (CTA) and a Chartered Accountant and has lectured extensively for the Irish Tax Institute. Laura is also an ITI BMW Branch Network representative and Chair of the West CTA Network.

Solicitors

Susan O’Connell studied law at University College Dublin, trained in McCann FitzGerald and qualified as a solicitor in 1996. Susan became a partner in McCann FitzGerald in 2002, leading the Private Client department of the firm for the following ten years, until the establishment of O’Connell Brennan in February 2012. Susan specialises in personal estate and tax planning, wills and succession, the transfer of assets by gift or inheritance, trusts (both domestic and international), the administration of estates and contentious probate and trust issues. She has written and lectured extensively and authored the Irish chapters of “Planning and Administration of Offshore and Onshore Trusts” and “International Trust Precedents” and co-authored the Irish chapter of “Offshore Service”. Susan is a former chairperson of the Society of Trust and Estate Practitioners (STEP) Ireland. She is also an AITI Chartered Tax Adviser (CTA) and a member of the International Academy of Trust and Estate Law. Saibh Young is EMEA Head of Tax, at Nomura International plc, London. She is a fellow of the Association of Chartered Certified Accountants and an AITI Chartered Tax Adviser (CTA). She trained and qualified with KPMG in Dublin. Prior to joining Nomura, Saibh was a Managing Director and member of the Global Tax Management team at Bear Stearns.


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Tax, Finance and Mobility for Growth and Export

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4b.i Your Transfer Pricing Policy in Action 4b.ii Managing an International Tax Function

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