Exhibit 8.1

                                           , 2002

SmartForce PLC
900 Chesapeake Drive
Redwood City, CA 94063

   Re: Merger pursuant to the Agreement and Plan of Merger and Reorganization
       (the "Agreement"), dated January 16, 2002, among SmartForce PLC, a
       public limited liability company organized under the laws of the
       Republic of Ireland ("SmartForce"), Atlantic Acquisition Corp., a
       Delaware corporation and wholly-owned subsidiary of SmartForce (the
       "Merger Sub"), and Centra Software, Inc., a Delaware corporation
       ("Centra").

Ladies and Gentlemen:

   We have acted as counsel to SmartForce in connection with the proposed
merger (the "Merger") of Merger Sub with and into Centra pursuant to the
Agreement. The Merger and certain proposed transactions incident thereto are
described in the Registration Statement on Form S-4 (the "Registration
Statement") of SmartForce, which includes the Proxy Statement/Prospectus of
SmartForce and Centra (the "Proxy Statement/Prospectus"). This opinion is being
rendered pursuant to the requirements of Item 21(a) of Form S-4 under the
Securities Act of 1933, as amended. Unless otherwise indicated, any capitalized
terms used herein and not otherwise defined have the meaning ascribed to them
in the Proxy Statement/Prospectus. All section references, unless otherwise
indicated, are to the Internal Revenue Code of 1986, as amended (the "Code").

   You have requested our opinion regarding the qualification of the Merger as
reorganization within the meaning of Section 368(a) of the Code. In delivering
this opinion, we have reviewed and are relying upon the truth and accuracy at
all relevant times (without any independent investigation or examination
thereof) the Agreement, tax representation letters delivered to us by Centra,
SmartForce and Merger Sub, respectively (the "Tax Representations"), and such
other documents, records and instruments as we have deemed necessary or
appropriate as a basis for our opinion.

   In connection with rendering this opinion, we have also assumed (without any
independent investigation or examination thereof) that:

      1. Original documents (including signatures) are authentic, documents
   submitted to us as copies conform to the original documents, and there has
   been due execution and delivery of all documents where due execution and
   delivery are prerequisites to effectiveness thereof;

      2. Any statement made in any of the documents referred to herein "to the
   knowledge of" or "to the best of the knowledge of" any person or party or
   similarly qualified is correct without such qualification;

      3. All facts, statements, covenants, representations and warranties
   contained in any of the documents referred to herein or otherwise made to us
   (including, without limitation, the Agreement and the Tax Representations)
   are true and correct in all respects and no actions have been (or will be)
   taken which are inconsistent with such positions;

      4. The Merger will be consummated in the manner contemplated by the Proxy
   Statement/Prospectus and in accordance with the terms of the Agreement
   without any waiver, breach or amendment of any covenant, condition, or other
   provision thereof, and the Merger will be effective under applicable state
   law; and

      5. SmartForce and Centra will report the Merger on their respective
   federal income tax returns in a manner consistent with the opinion set forth
   below.



SmartForce PLC
           , 2002
Page 2


   Because this opinion is being delivered prior to the Effective Time of the
Merger, it must be considered prospective and dependent on future events. There
can be no assurance that changes in the law will not take place which could
affect the U.S. federal income tax consequences of the Merger or that contrary
positions may not be taken by the Internal Revenue Service.

   Based on our examination of the foregoing items and subject to the
assumptions, exceptions, limitations and qualifications set forth herein, we
are of the opinion that, as of the date hereof, for federal income tax
purposes, the Merger will be a reorganization within the meaning of Section
368(a) of the Code. In the event any one of the facts, statements,
descriptions, covenants, representations, warranties or assumptions upon which
we have relied to issue this opinion is incorrect, our opinion might be
adversely affected and may not be relied upon.

   This opinion represents and is based upon our best judgment regarding
current federal income tax laws including the Code, existing judicial
decisions, administrative regulations and published rulings and procedures. Our
opinion is not binding upon the Internal Revenue Service or the courts, and
there is no assurance that the Internal Revenue Service will not successfully
assert a contrary position. No assurance can be given that future legislative,
judicial or administrative changes will not adversely affect the accuracy of
the conclusions stated herein. Nevertheless, we undertake no responsibility to
advise you of any new developments in the application or interpretation of the
federal income tax laws.

    This opinion addresses only the qualification of the Merger as a
"reorganization" as defined in Code Section 368(a). This opinion does not
address any other federal tax consequence or any state, local, or foreign tax
consequences that may result from the Merger or any other transaction
(including any transaction contemplated by the Agreement or undertaken in
connection with or in contemplation of the Merger).

   This opinion is furnished to you solely for use in connection with the
Registration Statement. We hereby consent to the filing of this opinion as an
exhibit to the Registration Statement. We also consent to the reference to our
firm name wherever appearing in the Registration Statement with respect to the
discussion of the material U.S. federal income tax consequences of the Merger,
including the Proxy Statement/Prospectus constituting a part thereof, and any
amendment thereto. In giving this consent, we do not thereby admit that we in
the category of persons whose consent is required under Section 7 of the
Securities Act of 1933, as amended, or the rules and regulations of the
Securities and Exchange Commission thereunder, nor do we thereby admit that we
are experts with respect to any part of such Registration Statement within the
meaning of the term "experts" as used in the Securities Act of 1933, as
amended, or the rules and regulations of the Securities and Exchange Commission
thereunder.

                                          Very truly yours,

                                          WILSON SONSINI GOODRICH & ROSATI
                                          Professional Corporation