Ireland–MNE Tax

Mickael Duquenne, Senior Manager and Pascal Luquet, Partner, at Grant Thornton Société d’Avocats, Paris, discuss a December 11 landmark decision of France’s Supreme Administrative Court concluding that an Irish company had a permanent establishment in France . . .

Africa

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

January 5, 2021

Europe

Facebook to wind up Irish divisions holding IP in response to tax law change: Julia Kollewe / The Guardian→

January 5, 2021

Americas

The end of the “double-Irish” tax structure means that a greater share of MNE profits are taxed in the US where the R&D generating the profits is undertaken: Seamus Coffey / Irish Examiner→

January 4, 2021

Europe

Ireland updates guidance on DAC6 mandatory disclosure regime: Irish Tax and Customs→

December 23, 2020

Europe

Updated Ireland R&D tax credit guidance addresses plant and machinery, reflects UK’s withdrawal from EU: Irish Tax and Customs→

December 22, 2020

Europe

Ireland provides guidance for taxpayers seeking to rely on private tax rulings issued in 2015 for periods after January 1, 2020: Irish Tax and Customs→

December 17, 2020

Europe

Ireland tax office outlines procedure and operation of co-operative compliance framework for large corporates: Tax and Duty Manual→

December 16, 2020

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Europe

Ireland updates tax manual to reflect updates to country-by-country reporting user guide and XML schema: Irish Tax and Customs→

November 30, 2020

Europe

Irish guidance addresses new VAT rules for cross-border business-to-consumer e-commerce activities: Tax and Duty Manual→

November 20, 2020

Europe

Ireland updates guidance on R&D tax credit refunds: Irish Tax and Customs→

November 11, 2020

Europe

Irish High Court rejects Perrigo’s challenge to procedural issues unrelated to merits of USD 1.9 billion tax case involving tax rate applicable to IP sales: Conor Humphries / Reuters→

November 4, 2020

Europe

Ireland provides guidance on DAC6 reporting of cross-border arrangements: Irish Tax and Customs→

November 3, 2020

Europe

Ireland releases tax bill, announces plan to enact interest deduction limits from 2022

October 28, 2020

Warren Novis, BDO Ireland, Dublin, discusses Ireland’s Finance Bill 2020, released October 22, which includes several tax provisions affecting multinational enterprises and Ireland’s plans to enact EU-compliant interest deduction limitations . . .

Europe

EU Commission appeals Apple State aid ruling

September 25, 2020

The European Commission today announced that it has appealed the EU General Court’s ruling in the Apple State aid case to . . .

Europe

Ireland proposes revisions to investment limited partnership structure: Ireland Department of Finance→

September 23, 2020

Europe

EU Commission will announce whether it will appeal Apple/Ireland tax ruling closer to September 25 deadline for filing an appeal, Vestger says: Naomi O’Leary, Joe Brennan / Irish Times→

September 18, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Asia-Pacific

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

August 10, 2020

Gela Barshovi a tax adviser and managing partner of TPsolution, Tbilisi, discusses the Republic of Georgia’s July 23 publication of the synthesized text of tax treaties with five countries, as amended by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting . . .

Asia-Pacific

Trump trade adviser Peter Navarro says tax incentives in Ireland, Singapore, Switzerland, India, China that lure pharmaceutical manufacturing away from US are a “significant” problem: Brian O’Donovan / RTÉ→

August 10, 2020

Europe

EU court reaches surprising conclusions in Apple state aid case

July 15, 2020

Aisling Donohue, a Partner, Andersen, Dublin, discusses today’s ruling by the General Court of the European Union quashing a decision by the European Commission that Ireland had granted Apple an illegal State aid, focusing on the likely next steps in this litigation . . .

Americas

EU General Court should conclude that Apple branch’s stateless income should not be taxed in Ireland because assets, functions, risks not located there, Irish economist says: Seamus Coffey→

July 9, 2020

Europe

EU General Court decisions on Ireland v Commission, Apple v Commission expected next week

July 9, 2020

The EU General Court will release its decisions in the Apple state aid cases — Ireland v Commission and Apple Sales International . . .

Europe

Ireland updates tax guidance on foreign earnings deduction

April 7, 2020

Irish Tax and Customs today updated its guidance regarding the . . .

Europe

Ireland’s tax revenues may not drop despite coronavirus slowdown because receipts from MNEs in manufacturing, ICT, finance sectors may hold steady or even rise, economist says: Seamus Coffey (@seamuscoffey) / Twitter→

March 31, 2020

Europe

Ireland announces tax measures to help SMEs experiencing cash flow difficulties from COVID-19: Irish Tax and Customs→

March 18, 2020

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

Ireland

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

Ireland updates tax guidance on controlled foreign company rules to reflect Finance Act 2020 changes: Irish Tax and Customs→

Ireland updates tax guidance on company residence to reflect the end of transition period provided in the Finance Act 2014: Irish Tax and Customs→

Ireland updates DAC6 guidance to clarify filing procedure when a disclosure is subject to legal privilege: Irish Tax and Revenue→

Ireland updates Corporate Tax Roadmap: Ireland Department of Finance →

French High Court in Valueclick interprets tax treaty permanent establishment rules

Using US IRS data, authors conclude that Bermuda, Ireland, Netherlands are US MNEs’ most important tax havens: Petr Janský, Javier Garcia-Bernando, Thomas Tørsløv /Springer→

Facebook to wind up Irish divisions holding IP in response to tax law change: Julia Kollewe / The Guardian→

The end of the “double-Irish” tax structure means that a greater share of MNE profits are taxed in the US where the R&D generating the profits is undertaken: Seamus Coffey / Irish Examiner→

Ireland updates guidance on DAC6 mandatory disclosure regime: Irish Tax and Customs→

Updated Ireland R&D tax credit guidance addresses plant and machinery, reflects UK’s withdrawal from EU: Irish Tax and Customs→

Ireland provides guidance for taxpayers seeking to rely on private tax rulings issued in 2015 for periods after January 1, 2020: Irish Tax and Customs→

Ireland tax office outlines procedure and operation of co-operative compliance framework for large corporates: Tax and Duty Manual→

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

Ireland updates tax manual to reflect updates to country-by-country reporting user guide and XML schema: Irish Tax and Customs→

Irish guidance addresses new VAT rules for cross-border business-to-consumer e-commerce activities: Tax and Duty Manual→

Ireland updates guidance on R&D tax credit refunds: Irish Tax and Customs→

Irish High Court rejects Perrigo’s challenge to procedural issues unrelated to merits of USD 1.9 billion tax case involving tax rate applicable to IP sales: Conor Humphries / Reuters→

Ireland provides guidance on DAC6 reporting of cross-border arrangements: Irish Tax and Customs→

Ireland releases tax bill, announces plan to enact interest deduction limits from 2022

EU Commission appeals Apple State aid ruling

Ireland proposes revisions to investment limited partnership structure: Ireland Department of Finance→

EU Commission will announce whether it will appeal Apple/Ireland tax ruling closer to September 25 deadline for filing an appeal, Vestger says: Naomi O’Leary, Joe Brennan / Irish Times→

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

Georgia publishes amended text of tax treaties with Iceland, Ireland, Finland, Luxembourg, Slovenia

Trump trade adviser Peter Navarro says tax incentives in Ireland, Singapore, Switzerland, India, China that lure pharmaceutical manufacturing away from US are a “significant” problem: Brian O’Donovan / RTÉ→

EU court reaches surprising conclusions in Apple state aid case

EU General Court should conclude that Apple branch’s stateless income should not be taxed in Ireland because assets, functions, risks not located there, Irish economist says: Seamus Coffey→

EU General Court decisions on Ireland v Commission, Apple v Commission expected next week

Ireland extends DAC6 reporting requirement by six months: Irish Tax and Customs→

Ireland extends DAC6 reporting deadlines to September 30 consistent with EU agreements: Irish Revenue→

Ireland updates guidance on allowances for scientific research: Tax and Duty Manual→

Ireland postpones dividend withholding tax real-time reporting for dividend distributions: Irish Revenue→

Synthesized text Ireland-Lithuania tax treaty as amended by MLI released: Irish Revenue→

Synthesized text of Ireland-Singapore tax treaty as amended by MLI released: Irish Revenue→

Ireland advises of change to tax treatment of royalty income under treaty with Lithuania

Ireland updates tax guidance on foreign earnings deduction

Ireland’s tax revenues may not drop despite coronavirus slowdown because receipts from MNEs in manufacturing, ICT, finance sectors may hold steady or even rise, economist says: Seamus Coffey (@seamuscoffey) / Twitter→

Ireland announces tax measures to help SMEs experiencing cash flow difficulties from COVID-19: Irish Tax and Customs→