Ireland–MNE Tax

Europe

Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→

April 18, 2022

Europe

Ireland revises guidance on mandatory disclosure of reportable cross-border arrangements (DAC6) to reflect changes introduced in Finance Act 2021 and to provide additional guidance on various hallmarks, filing obligations, nexus, and the main benefit test: Irish Revenue→

April 12, 2022

Europe

The Advocate General’s opinion in the Fiat appeal: a plea for legal certainty

March 14, 2022

Leopoldo Parada, University of Leeds School of Law, analyzes the three grounds of appeal in the Fiat Chrysler Finance Europe v Commission case and warns that if the European Court of Justice agrees to follow the Advocate General’s opinion, there may be important ramifications that go beyond this transfer pricing case.

Americas

Switzerland will implement global minimum tax by constitutional amendment

January 13, 2022

The Swiss Federal Council on January 12 decided that it will implement the 15% global minimum tax agreed by the OECD Inclusive Framework through a constitutional amendment with an aim to ensure the measure comes into force as of January 1, 2024; the approach is intended to . . .

Europe

Ireland updates mutual agreement procedure guidelines for tax disputes

December 28, 2021

The Irish Revenue Department on December 23 published updated guidelines for requesting mutual agreement procedure (MAP) assistance for resolving cross-border tax and transfer pricing disputes; the updates incorporate a . . .

Europe

Ireland weighs move to territorial tax system

December 23, 2021

The Irish Department of Finance on December 22 opened a public consultation inviting comments on a possible transition to a territorial tax regime for corporations; such a system “could be simpler and provide greater certainty for businesses — but would also have to be accompanied by . . .

Accounting

Ireland consults on adoption of public country-by-country tax reporting

December 21, 2021

The Irish government is seeking input, through a consultation published December 20, on its implementation of the new EU directive requiring public country-by-country reporting of income tax information by certain large . . .

Europe

Ireland updates R&D tax credit manual

December 15, 2021

The Irish government on December 14 released an updated version of its tax manual on the research and development (R&D) tax credit, clarifying certain matters for small and . . .

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

November 23, 2021

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Europe

Isle of Man and Ireland signed tax treaty protocol November 19, underling countries’ commitments to ‘latest international standards in respect of Base Erosion and Profit Shifting’: Isle of Man government→

November 19, 2021

Europe

Irish Finance Minister outlines reasoning in joining global tax deal

November 10, 2021

The benefits to Ireland of joining the OECD/G20 global tax deal “far outweigh” the downsides of remaining outside the deal, which would carry “very real risks,” Irish Finance Minister Paschal Donohoe explained in a November 10 address to . . .

Accounting

Ireland considers new tax measures for outbound payments

November 5, 2021

The Irish Department of Finance on November 5 launched a public consultation on the introduction of new corporate tax rules applicable to outbound payments of interest, royalties, and dividends; the measures would deny . . .

Asia-Pacific

Mauritania becomes 141st country to join global tax ‘Inclusive Framework’

November 4, 2021

The OECD Inclusive Framework gains another member, with the northwestern Africa country of Mauritania joining as the 141st member, according to a November 4 OECD release. Mauritania is also joining the October 8 global tax pact.

Americas

UK consults on introduction of corporate re-domiciliation regime

November 2, 2021

The UK government on October 27 opened a consultation on the possibility of introducing a “corporate re-domiciliation” regime to make it easier for companies to relocate to the UK while maintaining . . .

Africa

Global tax deal to proceed with G20 endorsement, but not all is resolved

November 1, 2021

At the end of their October 30–31 summit in Rome, the leaders of the G20 adopted a declaration supporting the implementation of new international tax rules – urging the OECD “to swiftly develop the model rules and multilateral instruments” necessary to . . .

Europe

Ireland tax guide reviews mandatory disclosure regime

October 25, 2021

Irish Revenue on October 22 incorporated into its tax manual guidelines on the mandatory disclosure regime, setting out guidance notes regarding the required reporting of certain transactions that are . . .

Digital Economy

Irish Finance Bill 2021 adopts transfer pricing, international tax changes

October 22, 2021

The Finance Bill 2021 released by the Irish government on October 21 sets out legislative changes related to transfer pricing, anti-tax avoidance measures, planned tax treaty ratifications, and various . . .

Accounting

Ireland 2022 budget’s tax changes include 15% corporate rate, new incentives

October 12, 2021

The Irish government’s Budget 2022, announced October 12, includes an increase in the corporate tax rate to 15% in line with last week’s OECD tax agreement, expanded relief for start-up companies, a new tax credit for . . .

Africa

Global tax talks reach ‘critical mass’ for landmark deal by tweaking details

October 8, 2021

The historic October 8 agreement on a global minimum tax and new rules for allocating taxing rights for large multinationals both firms up issues left open in the initial July statement and reflects concessions that were made to bring into the deal a few new countries, including . . .

Americas

OECD and Ireland strike tax deal as others in EU line up, developing countries shrug

October 7, 2021

Ireland announced October 7 that it is joining the OECD tax deal, cutting the holdouts down to just five nations out of the 140 in the Inclusive Framework that are scheduled to meet Friday, October 8, to . . .

Americas

Switzerland, Estonia, Ireland seek concessions in global tax deal

October 4, 2021

OECD Secretary-General Mathias Cormann told the Swiss Finance Minister that he personally does not see a consensus on a global minimum tax at a rate above 15%, attempting to allay Swiss concerns about the Inclusive Framework’s July statement referring to . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Europe

Ireland reportedly ready to increase corporate tax rate to 15% if OECD agrees to strike from agreement term that global minimum tax be ‘at least’ 15%: Pat Leahy & Cormac McQuinn / Irish Times→

September 27, 2021

Europe

American Chamber of Commerce in Ireland advises Irish Finance Minister that it’s not in country’s interests to resist a global minimum tax agreement: Arthur Beesley & Naomi O’Leary / Irish Times→

September 20, 2021

Estonia

EU state of the union address calls for tax reforms

September 17, 2021

European Commission President Ursula von der Leyen stressed the importance of fair taxation and initiatives to expand the tax base in her 2021 state of the union address on September 15, emphasizing . . .

Europe

Ireland 2022 budget strategy papers address corporate, international tax policies

September 16, 2021

The Irish Department of Finance on September 16 published a series of papers examining tax policy in advance of Budget 2022, including issues related to corporate tax and international . . .

Europe

‘Single malt’ multinational tax avoidance techniques still being exploited via Ireland-Malta intercompany transfers despite 2019 agreement between the countries to end the practice, charity claims: Pat Leahy / The Irish Times→

September 15, 2021

Europe

Ireland clarifies transfer pricing rules for ‘section 110’ companies

September 7, 2021

Irish Revenue on September 6 updated its guidance on qualifying companies under section 110 to address uncertainty regarding the application of transfer pricing rules and . . .

Americas

European banks’ tax haven use persists but varies widely, study finds

September 7, 2021

Large European banks report an average of 20% of their profits in tax havens, but some report more than half of their profits in such jurisdictions while others report none, according to a September 6 report from the EU Tax Observatory . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Europe

Irish Central Bank Governor says he’s not significantly worried about effect of corporate tax rate change on Irish economy, but impact will depend on internationally agreed rate, carve-outs: Johanna Treeck / Politico→

August 3, 2021

Africa

Ireland, Lithuania, Hungary offer lowest tax rates for R&D, OECD study finds

August 2, 2021

An OECD taxation working paper on corporate effective tax rates for research and development (R&D) released on July 29 reports that the effective average tax rate on R&D investments in Ireland, Lithuania, and Hungary range from -2% to -4% – suggesting . . .

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Europe

Ireland and Kenya signed double tax treaty on July 21: Irish Department of Foreign Affairs→

July 28, 2021

Americas

EU continues to wrangle over global minimum tax’s carve-outs, rate

July 26, 2021

A July 21 study from the EU Tax Observatory predicts that a substance carve-out under the agreement for a proposed global minimum tax could exacerbate tax competition and would reduce by 15% to 30% the tax revenues that the EU would otherwise . . .

Americas

Ireland seeks input on OECD tax proposals’ impact on Irish tax policy

July 20, 2021

The Irish Department of Finance on July 20 opened a consultation on implications for Ireland’s corporate tax policy arising from the two-pillar proposal for overhauling the international tax framework recently . . .

Ireland

Global minimum tax negotiations could land at ‘a bit higher’ rate than 15%, OECD tax director Pascal Saint-Amans says, adding that agreement will proceed with or without Ireland: Irish Times→

July 19, 2021

Europe

Ireland will likely give up its 12.5% corporate tax rate later this year in response to OECD tax agreement impetus, Irish government officials reportedly suggest: Daniel McConnell / Irish Examiner→

July 15, 2021

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin