Ireland’s Department of Finance is seeking stakeholders’ views on implementing into Irish legislation the EU tax directive on Pillar Two rules, also known as Global anti-Base Erosion (GloBE) rules.Continue Reading
Ireland
Transfer pricing news, BEPS news, and international tax news in Ireland
Ireland consulting on tax changes to tackle double non-taxation
Ireland’s Department of Finance is consulting stakeholders on new tax measures that would prevent double non-taxation arising from outbound payments to low or no tax jurisdictions.Continue Reading
Ireland gazettes public country-by-country tax reporting
Ireland has signed into law a new public country-by-country tax reporting requirement.Continue Reading
Ireland boasts strong corporate tax receipts
Ireland’s Department of Finance has revealed that corporation tax receipts amounted to EUR 21.1 billion in the year to end-November.Continue Reading
Spain, Ireland fastest in closing MAP cases under tax treaties
Spain has been awarded for taking the shortest time in closing transfer pricing cases under the mutual agreement procedure (MAP) set out in tax treaties.
The 2021 MAP Statistics were presented during the OECD Tax Certainty Day, where tax officials and stakeholders took stock of the tax certainty agenda and discussed ways to further improve dispute prevention and resolution. The MAP Award is given in recognition of efforts by competent authorities in dealing with MAP cases.Continue Reading
Ireland says no to global minimum corporate tax proposal
The consultation will run until September 10.Continue Reading
Ireland confirms new DAC6 reporting format
DAC6 Schema Version 1.1 is applicable for all exchanges until July 31, 2021.Continue Reading
Paschal Donohoe discusses international tax reform
Donohoe said that he desired “an outcome that is a fair and balanced compromise by and for all the 139 countries in the OECD Inclusive Framework.”
Ireland’s commitment remains resolute towards reaching an agreement on digital economy taxation, Ireland’s Minister for Finance, Paschal Donohoe, has said.Continue Reading
Ireland consulting on tax treaty policy
The consultation period will run until May 7, 2021.
Ireland’s Finance Minister on April 7 launched a public consultation on Ireland’s future tax treaty policy, particularly in the context of potential outcomes of international tax discussions at the OECD.Continue Reading
OECD releases new MAP peer review reports
The reports evaluate the progress made by these eight jurisdictions in implementing any recommendations resulting from their stage 1 peer review. They take into account any developments in the period January 2018- August 2019 and build on the MAP statistics for 2016-2018.Continue Reading
Ireland updates corporate tax roadmap
According to the update, Ireland will seek to implement interest limitation rules in accordance with the Anti-Tax Avoidance Directive (ATAD) standard; legislate for new international tax transparency rules for digital platforms; legislate for reverse hybrids aspect of ATAD anti-hybrid rules; adopt the authorized OECD approach for transfer pricing of branches; and consider actions that may be needed in respect of outbound payments from Ireland and our wider withholding tax regime.Continue Reading
Ireland updates DAC6 guidance
The Tax and Duty Manual Manual on DAC6 has been updated in a number of respects. The updates are set out in Appendix V. Continue Reading
Brussels to appeal Apple State aid tax case in Ireland
In July 2020, the General Court annulled the Commission’s 2016 decision concluding that Ireland granted illegal State aid to Apple through selective tax breaks.Continue Reading
Irish tax authority extends DAC6 timelines by six months
The 30-day time period will commence on January 1, 2021. Continue Reading
Irish tax guidance on transfer pricing correlative adjustments explained
By Catherine O’ Meara (Partner, Matheson, Dublin)
The ability to claim relief from double taxation for transfer pricing adjustments is increasingly important as taxpayers face audits worldwide. The Irish Revenue Commissioners (“Revenue”) have recently issued new guidelines for taxpayers seeking correlative adjustments (“CA Guidance”) in Ireland for transfer pricing adjustments by tax treaty partner jurisdictions. Continue Reading
EU Commission urges Ireland, Netherlands, four others to tackle aggressive tax planning
The six member states are: Cyprus, Hungary, Ireland, Luxembourg, Malta, and the Netherlands.Continue Reading
New tax treaty between Ireland, Netherlands enters into force
The new treaty will be effective from January 1, 2021. Continue Reading
EU Commission warns Austria, Ireland to transpose interest limitation rules
The Commission may bring the cases before the Court of Justice of the EU if Austria and Ireland do not act by February 1, 2020.Continue Reading
Kevin Norton joins Deloitte’s transfer pricing practice
Transfer pricing specialist Kevin Norton has joined Deloitte Ireland’s tax team as partner.Continue Reading
Ireland Transfer Pricing Feedback Statement Explained
By Catherine O’ Meara (Partner, Matheson, Dublin)
The Irish Government recently published a Transfer Pricing Rules Feedback Statement, which confirms that changes to the country’s transfer pricing rules and their implementation are forthcoming.Continue Reading
Ireland updating transfer pricing regime
The proposals would be included in Finance Bill, 2019 and, if enacted, would apply for chargeable periods commencing January 1, 2020.Continue Reading
Ireland deposits BEPS MLI to tackle tax avoidance
For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading
New EU corporate tax avoidance rules enter into force
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
New Agreement between Ireland and Malta to counteract the ‘Single Malt’ tax structure
By Catherine O’ Meara (Partner, Matheson, Dublin) and Brian Doohan (Senior Associate, Matheson, Dublin)
On November 27, 2018, Ireland’s Finance Minister Paschal Donohoe announced the details of a Competent Authority Agreement between Ireland and Malta (Agreement). The clear aim of the Agreement is to end what is referred to as the “Single Malt” tax structure.Continue Reading
France, Germany propose new digital tax plan
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
Ireland Consulting on Corporate Anti-Tax Avoidance Measures
On November 14, 2018, Ireland’s Department of Finance published for public comments a consultation document on the hybrid mismatch and interest limitation measures to be introduced as part of the implementation of the EU Anti-Tax Avoidance Directives (ATAD and ATAD2).
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Ireland Signs Order to Ratify BEPS Convention
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Ireland’s Government has signed an Order to facilitate ratification of the OECD’s Multilateral Instrument to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS).Continue Reading
Mutual Agreement Procedure Statistics Published for 2017
The OECD on October 10 published its 2017 mutual agreement procedure (MAP) statistics covering 85 tax jurisdictions.
According to the 2017 MAP statistics, new transfer pricing MAP cases are up by 25 percent and other MAP cases by 50 percent. Anecdotal evidence suggests that the increase in new MAP cases is due to a range of factors including the effects of the new reporting framework and increased awareness of and expectations from taxpayers about MAP, the OECD noted.Continue Reading
Ireland Finance Bill 2018 to Include International Tax Measures
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Ireland would introduce key international tax measures in Finance Bill 2018 to comply with the EU Anti-Tax Avoidance Directive, Finance Minister Paschal Donohoe said in his 2019 Budget Statement released on October 9. The Finance Bill 2018 is due to be published on October 18.Continue Reading
EU Commission to Drop Infringement Proceedings in Ireland-Apple State Aid Decision
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The EU Commission is now to withdraw infringement proceedings against Ireland as the Government has now completed full recovery of the alleged State aid from Apple.Continue Reading
Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
Ireland’s Finance Minister Paschal Donohoe has published the country’s Corporation Tax Roadmap outlining the steps that the Government will take in the area of international tax law over the next few years.Continue Reading
MAP Peer Review Reports Out for Australia, Ireland, Japan, Five Others
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
The OECD on August 30 published stage 1 mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand, and Portugal.Continue Reading
MNEs Using Irish, Dutch Tax Systems to Avoid Tax: Commission Report
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).Continue Reading
Ireland’s FM Discusses Corporate Tax Rate, US Tax Reform
The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597).
In his recent address to the Irish Tax Institute, Ireland’s Finance Minister, Paschal Donohoe, outlined views on critical tax issues such as the country’s low corporate tax rate, the impact of US tax reforms, and digital taxation.Continue Reading
Ireland, Ghana Sign New Tax Treaty
Ireland and Ghana signed a new tax treaty on February 7, 2018. The procedures to ratify the treaty are underway.
Ireland is also negotiating and renegotiating existing treaties with foreign jurisdictions.
According to the tax authority, Ireland’s existing treaty base will also be updated to incorporate provisions set out in the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting.
Ireland, Kazakhstan Tax Treaty Effective
The new tax treaty between Ireland and Kazakhstan became effective on January 1, 2018.
The tax treaty, which was signed by both countries in April 2017, entered into force on December 29, 2017.
Ireland Tax Authority Accepting CbC Reports
The Irish Tax and Customs is has opened the filing facility for the receipt of country-by-country (CbC) reports for fiscal years ending in 2016.Continue Reading
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