- Professor Gerardine Doyle
Show/hide contentOpenClose All
Curricular information is subject to change
Having completed this module students will be able to:
1. Understand and critique national and international tax policies surrounding the aviation sector.
2. Understand the impact of tax residence/ permanent establishment /taxable presence in the context of aircraft leasing.
3. Understand income tax considerations for senior executives of aircraft leasing companies
4. Explain the trading status of aircraft leasing companies drawing upon case law and revenue rulings.
5. Explain the taxation treatment of lessors and lessees and the link to their accounting treatment.
6. Critique the impact of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda on the aircraft leasing sector.
Topics we shall explore:
1. An Introduction to Tax, Tax Policy Making, Tax avoidance and tax evasion
2. The charge to tax: The meaning of tax residence for individuals and companies, income tax considerations for senior executives of aircraft leasing companies
3. The meaning of a trade and the trading status of aircraft leasing companies
• Badges of Trade, Revenue Rulings re trading status of aircraft leasing companies
• Income qualifying for 12.5% corporate tax rate
4. Tax depreciation / capital allowances and the aircraft leasing sector
• The meaning of plant and industrial building
• Qualifying conditions for tax depreciation – wear and tear allowances, balancing allowances and charges
• Tax depreciation for aircraft in Ireland, including MRO
5. Taxation of Lessors and Lessees
• The link between lease accounting and the taxation of leases
• The concept of deferred tax
• Disposal of leased assets – the tax treatment of gains and losses on disposal
• The tax treatment of foreign exchange transactions
• Aercap Annual Report
6. Base Erosion and Profit Shifting (BEPS) and its impact on the aircraft leasing sector, Module Wrap Up.
Anna Scally, Partner KPMG: Topical Issues in the tax landscape
Joe O’Mara, Partner KPMG: Comparative international tax policies for aircraft leasing and typical ownership structures
Finance structures and related tax considerations
• Finance vehicles used – standard companies, S.110 companies
• Debt instruments used
Martin McCoy, SMBC Aviation Capital (video link from Hong Kong)
Transfer tax considerations when buying and selling an aircraft
• Scope of taxes – sales taxes, capital gains taxes, stamp duties, customs duties
• Nature of interest transferring – full title, beneficial interest
• Tax treaty protection
• Tax clauses in legal agreements
|Student Effort Type||Hours|
|Specified Learning Activities||
|Autonomous Student Learning||
Not applicable to this module.
|Description||Timing||Component Scale||% of Final Grade|
|Continuous Assessment: Team Assignment Research-led teaching
Team Report, Team Presentation and Individual Reflection
Please see ‘Team Work Guidance for Students’ provided.
|Throughout the Trimester||n/a||Standard conversion grade scale 40%||No||
|Journal: Learning Journal
This is an individual assignment, encompassing all six topics within the module and material covered by our guest lecturers.
Please see ‘Learning Journal Guidance’ provided.
|Throughout the Trimester||n/a||Standard conversion grade scale 40%||Yes||
|Remediation Type||Remediation Timing|
|In-Module Resit||Prior to relevant Programme Exam Board|
• Feedback individually to students, post-assessment
• Group/class feedback, post-assessment
Not yet recorded.
|Practical||Offering 1||Week(s) - 0, 1, 2, 3, 4, 5||Mon 16:00 - 16:50||Online|
|Lecture||Offering 1||Week(s) - 0, 2, 4||Tues 08:30 - 09:50||Blended|
|Lecture||Offering 1||Week(s) - 1, 3, 5||Tues 08:30 - 09:50||Blended|
|Lecture||Offering 2||Week(s) - 0, 3, 5||Tues 08:30 - 09:50||Blended|
|Lecture||Offering 2||Week(s) - 1||Tues 08:30 - 09:50||Blended|
|Lecture||Offering 2||Week(s) - 2, 4||Tues 08:30 - 09:50||Blended|