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.

Ireland’s Corporation Tax Roadmap 2021 committed to review Ireland’s tax treaty policy, taking account of international developments, and publish a tax treaty policy statement by the end of 2021.

The Ministry is seeking responses on the following questions:

• Does Ireland’s tax treaty policy sufficiently cater for the evolving economic and business environment?
• Do you have any suggestions on how Ireland’s tax treaty policy can be enhanced, as a means to continue to facilitate economic opportunity into the future?
• Does Ireland’s tax treaty network sufficiently serve all business sectors in the economy?
• How can Ireland optimize its tax treaty priorities in the context of recent international tax reforms, notably at the OECD?
• What should the criteria be for prioritizing the negotiation and renegotiation of specific tax treaties in the years ahead?
• Are there any significant gaps in Ireland’s tax treaty network by reference to those criteria?
• Are there any specific areas of Ireland’s treaty policy which should be modified or tailored, in relation to developing country?
• Are there international best practices which Ireland can draw on to further enhance our approach to the specific circumstances of developing countries?
• When negotiating with developing countries, should more emphasis be placed on the UN Model Treaty? If so, please provide details.
• Should any specific standard positions, e.g. on source taxation, be adopted for treaties with developing countries?

Responses received on the policy issues detailed in this public consultation will form part of the consideration of the tax treaty policy statement, which will set out the broad parameters of Ireland’s treaty policy.

The consultation period will run until May 7, 2021.

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 at editor@transferpricingnews.com