Ireland–MNE Tax

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Accounting

Ireland consults on tax rules relating to interest limitation, hybrids

July 7, 2021

On July 2, the Irish Department of Finance opened for comment tax statements on the anti-reverse hybrid rule and interest limitation ratio rule, which will transpose requirements of the . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Ireland

Ireland will seek yet-to-be-defined compromise in global minimum tax talks with aim of preserving room for tax competition by smaller countries, Irish Finance Minster says: Silvia Amaro / CNBC→

June 21, 2021

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Europe

Royalty payments from Ireland to US jumped from about EUR 8 billion (USD 9.6 billion) annually to EUR 52 billion (USD 62.5 billion) in 2020, concludes report published on Irish government website: Seamus Coffey / University College Cork→

June 16, 2021

Europe

EU will propose minimum tax legislation if G20 reaches deal, commissioner says

June 14, 2021

The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 . . .

Asia-Pacific

India has little to gain under G7 tax agreement

June 14, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses how, for developing countries like India, the agreement that the G7 finance ministers reached on June 5 may bring little new tax revenue while imposing . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

Europe

Ireland’s new VAT rules for goods arriving into Ireland from non-EU countries enter into effect July 1, government notes: Irish Revenue→

June 4, 2021

Americas

Cyprus to oppose global min tax, EU public country-by-country reporting: eKathimerini.com→

June 4, 2021

Belgium

EU Tax Observatory’s first report predicts amounts to be collected under a minimum tax

June 2, 2021

The European Commission on June 1 announced the launch of the European Tax Observatory, an independent, EU-financed research laboratory to study and advise . . .

Americas

US agrees to 15% global minimum tax rate, boosting odds for Pillar 2 agreement

May 21, 2021

The US, which has been leading the push for a global agreement on a minimum corporate tax, has proposed a minimum tax rate of 15% – a concession from the 21% rate that the Biden Administration previously . . .

Europe

Ireland likely to oppose EU plan for unified tax base: Eoin Burke-Kennedy / The Irish Times→

May 20, 2021

Europe

Perrigo in discussions to settle $1.9B Irish tax bill, dispute concerns IP sales taxed as trading income at 12.5% instead of 33%: Seeking Alpha→

May 12, 2021

Europe

ECJ to this week hear Luxembourg’s appeal of the General Court’s decision in Fiat which approved the Commission’s use of the arm’s length principle to determine if a tax ruling gives rise to State aid: Seán McCárthaigh / Irish Times→

May 11, 2021

Europe

Ireland’s top 10 companies paid more than half of corporate tax last year: Seán McCárthaigh / The Irish Times→

May 10, 2021

Asia-Pacific

Global minimum tax opponents will not stop agreement, Saint-Amans says

May 4, 2021

Negotiations on a global minimum tax on corporations have the momentum that they need to reach an agreement now that France, Germany, and others have signaled support for recent US proposals. . .

Europe

Ireland amends R&D tax credit guidance to address rental costs

May 3, 2021

An updated version of Irish Revenue’s tax guidance on the research and development (R&D) tax credit, released April 28, adds a section on rent as a qualifying expenditure for R&D activities, among a few other revisions.

Europe

Ireland updates dividend withholding tax guidance to reflect Finance Act 2020 changes: Irish Revenue→

April 28, 2021

Americas

Google UK reports its 2020 financials: the transfer pricing implications

April 28, 2021

Dr. J. Harold McClure, New York City, discusses the transfer pricing implications of Google UK’s 2020 financial report . . .

Americas

Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says

April 22, 2021

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

Europe

Ireland positions itself as counterpoint to US in debate over global minimum tax

April 21, 2021

Irish Finance Minister Paschal Donohoe today confirmed that Ireland would resist the push for a global minimum tax to the extent that it would infringe on the country’s 12.5 percent corporate tax rate . . .

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Europe

Ireland reevaluating tax treaty policy

April 13, 2021

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Americas

Ireland may not agree to global minimum tax, minister says

April 7, 2021

There may not be agreement among all G20 nations on a global minimum corporate tax, according to Ireland’s Finance Minister and Eurogroup President Paschal Donohoe, who . . .

Europe

IRS claims Bristol Myers Squibb owes 1.38 billion in unpaid tax for inappropriate deductions following of transfer of patent rights to Irish sub, New York Times report says: Arlene Weintraub / Fierce Pharma→

April 1, 2021

Europe

Ireland updates guidance on capital allowances for intangible assets

April 1, 2021

Irish Revenue updated its tax manual guidance on capital allowances for intangible assets on March 31 to reflect amendments made by Finance Act 2020. . .

Europe

Ireland updates and expands tax guidance on anti-hybrid rules

March 31, 2021

Irish Revenue updated the anti-hybrid provisions in its tax manual on March 29 to reflect amendments made by Finance Act 2020 with respect to how the anti-hybrid rules apply to a worldwide system of taxation. . .

Europe

Ireland MEP says Parliament proposal to dispense with majority voting on tax issues that “distort” the single market skirt the treaty: Sarah Collins / Independent.ie→

March 24, 2021

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Europe

Public country-by-country reporting is inevitable, EU Commission official says: Naomi O’Leary / The Irish Times→

March 18, 2021

Europe

Ireland consults on adoption of authorized OECD approach for attributing profits to branches

March 17, 2021

Ireland’s Department of Finance on March 16 launched a public consultation on its proposal to adopt into Irish law the “authorized OECD approach” for the attribution . . .

Europe

Ireland updates guidance on self-certification system allowing payment of interest and royalties with deductions at the applicable tax treaty rate: Irish Tax and Revenue→

March 17, 2021

Europe

Ireland pays €1 million to the Netherlands for MAP settlement regarding the location of KPN insurance unit’s profits in 2014 and 2015: Mark Paul / The Irish Times→

March 16, 2021

Europe

Ireland updates DAC-6 rules on mandatory disclosure of cross-border arrangements

March 1, 2021

Irish Tax and Customs on March 1 updated its Tax and Duty manual section Part 33-03-03 providing guidance on reportable cross-border arrangements. The updated guidance removes the practice of allowing an intermediary not to disclose information about a person to whom they made

Europe

ActionAid, Christian Aid Ireland, Oxfam call on Ireland to drop opposition to public country-by-country reporting: Naomi O’Leary / The Irish Times→

February 24, 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