Ireland to Expand Transfer Pricing Rules by 2020, Introduce CFC Law

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 ( 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.

According to the Roadmap – issued on September 5 – the Government will introduce legislation in Finance Bill, 2018, to introduce controlled foreign company rules with effect from January 1, 2019.

Next, legislation will be introduced in Finance Bill, 2019, to introduce anti-hybrid rules, and to update and expand Ireland’s transfer pricing rules with effect from January 1, 2020.

Ireland will also take in Finance Bill, 2018, the final legislative steps required to allow Ireland to complete the ratification of the base erosion and profit shifting (BEPS) Multilateral Instrument.

The Government will hold further consultation processes on a range of issues including the technical design of complex anti-tax avoidance measures, and the Coffey Review recommendation to consider the potential impacts of moving to a territorial tax regime.

Minister Donohoe said: “I am delighted to publish this comprehensive Roadmap, which sets out a direction of travel for corporation tax reform over the coming years. The Roadmap highlights the significant actions that Ireland will continue to take to ensure that our corporation tax regime is transparent, sustainable, and legitimate.”

“It is vital to have a consensus-based, globally agreed approach to international tax. Tax rules need to continue to evolve to match the modern world, and that evolution can best take place through international agreement at the OECD and the BEPS Inclusive Framework. Ireland will continue to foster economic activity in Ireland, the EU and beyond by adapting and evolving our corporate tax regime while maintaining our key 12.5 percent rate.”