Taxation of Earn-out Payments in Ireland - Key Considerations Explored

Introduction

Aimed at accountants, tax advisors, solicitors and business owners in the Republic of Ireland, this new virtual classroom seminar will cover the principal tax considerations associated with the sale of an Irish company where all or part of the purchase price will be calculated by reference to the future performance of the company being sold.

Presented by tax expert Robert Dever of Pinsent Masons, this session will focus on the implications of an earn-out arrangement for the seller(s), especially from a capital gains tax perspective, and impact of the arrangement for any tax reliefs that a seller may be entitled to, either at the time of the sale or in the future.

Consideration will be given to potential structuring options around the earn-out to provide a better tax result and buyer-related considerations, including from a stamp duty perspective.

Following the session, you will have a better understanding of the relevance of anti-avoidance rules, applicability of withholding tax rules and exposure to payroll taxes in the context of earn-out arrangements.

What You Will Learn

This live and interactive session will cover the following:

• Tax implications from the sellers’ perspective, including capital gains tax considerations arising from unascertainable consideration rules and implications for applicable tax reliefs
• Tax implications from the buyer’s perspective, including stamp duty
• Applicability of anti-avoidance rules to earn-out arrangements
• Earn-outs and withholding tax considerations
• Payroll tax exposures associated with earn-out payments
• Structuring the earn-out in a tax-efficient manner and commercial considerations arising from same

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.