Ireland
Irish Budget 2018 makes makes only minor changes to corporate taxes
Jim Stewart, an Adjunct Professor in Finance at Trinity Business School, Trinity College, Dublin, writes that Irish budget 2018, released today, proposes to limit deductions for intellectual property expenditures, but contains few other changes directly affecting the Irish corporate tax regime . . .
Ireland initials tax treaty with Oman, treaties with Botswana, Ethiopia enter into effect
Ireland has concluded negotiations for a new tax treaty with Oman and expects the treaty to be signed shortly, Irish Revenue . . .
EU proposals for public country-by-country reporting, CCCTB should be rejected, Irish finance minister says
Ireland’s Minister for Finance Michael Noonan today expressed opposition to EU Commission proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country reporting, arguing that both measures are counterproductive . . .
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Apple may lose EU State aid dispute, tax experts say
The EU Commission, on December 19, released the public version of its decision, announced last August, determining that Ireland granted illegal State aid to Apple by issuing the company’s subsidiaries overly-generous private tax rulings. A lot is at stake, including . . .
Ireland appeals Apple state aid decision
The Irish government today filed suit to annul the EU Commission’s decision in the Apple case, which concluded that Ireland granted Apple about €13 billion (USD 14.5 billion) in illegal state aid by . . .
Ireland updates FATCA guidance
Irish Tax and Customs on March 21 released Frequently Asked Questions (FAQs) on FATCA . . .
Apple appeals State aid decision in EU court
Mary Cosgrove, a tax lecturer at the J. E. Cairnes School of Business & Economics at the National University of Ireland, Galway, provides an update of the EU Commission’s State aid challenge to tax rulings granted by Ireland to Apple . . .
Ireland says tax treaty with Ethiopia entered into force, updates status of treaties with Ghana, Oman, South Africa
Irish Revenue has announced that a new double taxation agreement with Ethiopia entered into force on August 12. The treaty, signed November 3, 2014, will . . .
Apple to argue in State aid case that Irish subs’ profits belong to US
Aisling Donohue, a tax partner at mgpartners, Dublin, discusses Apple’s grounds for appealing the EU Commission’s State aid decision against Ireland, published today in summary form, noting that Apple’s arguments diverge somewhat from Ireland’s arguments. . .
Ireland, US multinationals to face new tax landscape in 2018
Jim Stewart, Trinity Business School, Trinity College, Dublin discusses how EU tax authorities’ increasing challenges to the tax strategies of US multinationals, their access to information about MNE activities, US tax reform, and the net effect of ‘correlative adjustments,’ are creating a new tax environment for US MNEs, Ireland, and international taxation in general . . .
Hong Kong, Ireland agree to automatic exchange of information for tax purposes
Hong Kong and Ireland on June 8 signed an agreement for the automatic exchange of financial account information in tax matters beginning 2018, the Hong Kong government . . .
Luxembourg announces new tax treaty with Serbia; entry into force of protocols with Ireland, Mauritius, Lithuania and UAE; and law approving tax treaties with six other nations
The government of Luxembourg has announced that protocols signed with Ireland, Mauritius, Lithuania and United Arab Emirates entered into force on December 11 and . . .
EU committee publishes letters from 13 nations on tax ruling practices
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Ireland publishes text of tax provisions phasing out “double Irish” and proposing new MNE tax incentives
The Irish government on October 23 published Finance Bill 2014, which gives effect to the taxation-related measures previously announced in the government’s 2015 budget.
Included are changes to Ireland’s company residence rules which slowly close the “double Irish” corporate tax loophole. Beginning January 1, 2015, all . . .
Irish tax proposal will not eliminate “double Irish,” say attorneys: Even if Ireland eliminates the Irish incorporated non-resident company, the tax benefits of the “double Irish Dutch sandwich,” can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation under Ireland’s existing tax treaties with those nations, write Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.
Ireland’s tax authority provides commentary on tax code
Irish Tax and Customs on December 31 released guidance notes providing section-by-section commentary on many provisions of the Irish tax code. Included are the tax administration’s views on transfer pricing, anti-avoidance, double taxation relief, tax treaties, and charging and assessing nonresidents.
See, Notes for Guidance
Ireland and Pakistan sign tax treaty, text available
Ireland and Pakistan signed a tax treaty on April 16, Irish Revenue and Customs has announced. The agreement . . .
Ireland extends FATCA filing deadline
Irish Revenue on June 25 announced that, in response to industry request, it has extended the FATCA filing deadline for financial . . .
Irish tax proposal will not eliminate “double Irish,” say attorneys
Even if Ireland eliminates the Irish incorporated non-resident company, as proposed in 2015 Irish budget, the tax benefits of the “double Irish Dutch sandwich,”can still be achieved by setting up a Irish company managed and controlled in Malta or the UAE instead of a Caribbean nation because of provisions in Ireland’s existing tax treaties with those nations, writes Jeffrey L. Rubinger and Summer Ayers LePree of Bilzin Sumberg Baena Price & Axelrod LLP in an October 23 website post. See, Bilzin Sumberg.