Europe
Ireland
Europe
Etsy’s Irish subsidiary switches to an unlimited liability company, allowing it to conceal profits shifted to tax havens – Bloomberg Business
“Because of a change in how its Irish subsidiary is registered, Etsy no longer needs to publicly disclose basic financial information about that unit,” write Bloomberg’s Alex Barinka and Jesse Drucker. See: Bloomberg Business
Europe
Irish manual details new tax residency rule restricting “Double Irish” for some MNEs, other corporate tax changes
Irish Revenue on August 28 released five tax manuals on recent corporate tax law changes, including guidance on new tax residency rules that make it more difficult for multinationals to take advantage of the “Double Irish” tax loophole and rules that change capital allowances for . . .
Europe
Ireland consults on “knowledge box” tax regime for IP, agrees to OECD limits
Ireland’s Department of Finance on January 14 published a consultation document on a proposed “knowledge box” tax regime that will provide for a special lower rate of tax on income from intellectual property. The government did not disclose the proposed tax rate. The Irish government also said that it will adhere to OECD and EU . . .
Europe
Ireland regains its swagger in the tax arena
Aisling Donohue, a tax partner with mgpartners, Dublin, discusses Ireland’s unexpectedly large 2015 corporation tax receipts and the country’s likely response to the OECD/20 base erosion profit shifting (BEPS) recommendations and the EU proposals for a common consolidated corporate tax base (CCCTB) and a financial transactions tax.
Americas
Ireland publishes FATCA user guides
Irish Revenue on June 23 published three FATCA user guides . . .
Europe
Ireland updates guidelines on R&D tax credit, film tax relief
Irish Tax and Customs on January 13 released updated guidelines on calculating the research and development (R&D) tax credit that take into account new rules, effective tax years beginning January 1, which no longer require companies to subtract base year expenditures . . .
Europe
EU releases details of state aid probe into rulings granted by Ireland to Apple and by Luxembourg to Fiat
The European Commission on Sept. 30 published non-confidential versions of its decisions to open state aid investigations into private rulings granted to Apple in Ireland and Fiat in Luxembourg. . .
Europe
Ireland issues guidance on spontaneous exchange of tax rulings with EU nations
Irish Revenue on March 12 released guidance on how it will implement spontaneous exchange of tax ruling information with EU Member States. The directive applies with immediate effect. As a member of the EU, Ireland is subject to . . .
Europe
Europe
Ireland updates guidance on exit tax
Ireland’s Tax and Duty Manual has been updated with expanded information regarding the procedures that migrating companies should use to elect to defer their exit charge under the tax laws, Irish Tax and Customs announced on May 26. See, Revenue eBrief No. 53/15.
Americas
Irish finance minister says German/UK patent box proposal may disadvantage small countries, worries BEPS will target US MNEs
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
Europe
Ireland resolves 9 MAP cases in 2014, expands competent authority staff
Ireland resolved 9 mutual agreement procedure (MAP) cases with other nations in 2014, leaving inventory of 22 unresolved MAP cases by the end of that year, Irish Revenue said in a report, released on November 9. The report . . .
Europe
Americas
CRS report reveals extent of American MNE profit shifting, discusses tax reform options
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
Europe
Americas
Africa
Ireland and Zambia sign tax treaty, text available
Irish Revenue on April 22 released the text of a tax treaty signed by Ireland and Zambia on March 31. The agreement is . . .
Americas
New Irish fund vehicle permits US check-the-box election
Ireland’s Minister of Finance Micheal Noonan on March 11 signed an order to commence legislation that establishes the Irish collective asset-management vehicle (“ICAV”), a new Irish corporate vehicle for investment funds. The ICAV will be a corporate entity with . . .
Europe
Ireland expected to close “Double Irish” loophole
Ireland is expected to announce on October 14 that it will phase out the “Double Irish” tax loophole, reports Sam Schechner and Lisa Fleisher, The Wall Street Journal. See also, Padraic Halpin, Reuters and Arthur Beesley, Irish Times.
Europe
Ireland likely to lose EU state aid case involving Apple – Bloomberg Business
“Ireland will probably face censure from European authorities within months in relation to its tax dealings with Apple Inc.,” write Gaspard Sebag and Joe Brennan of Bloomberg Business, quoting unnamed sources. See: Bloomberg Business.
Europe
Ireland releases guidance on qualifying avoidance disclosures
Irish Tax and Customs on January 30 released guidance on qualifying avoidance disclosures under Section 811A(2A) Taxes Consolidation Act 1997. Under the
. . .
Europe
Germany and UK agree to modified nexus approach for IP regimes, existing arrangements grandfathered until 2021
Germany and the UK have agreed to a proposal that would put limits on preferential intellectual property regimes, including the UK’s patent box regime, for purposes of drafting uniform rules responding to Action 5 of the OECD/G-20 base erosion profit shifting (BEPS) plan. The compromise proposal breaks . . .
Africa
Ireland signs treaty with Ethiopia
Irish Tax and Customs has announced that Ireland signed a tax treaty with Ethiopia on November 3. The text of the treaty is not yet available. See, Irish Tax and Customs website.
Americas
Irish Revenue outlines FATCA treatment of holding companies and treasury companies
Irish Revenue on June 17 released guidance on the treatment of holding companies and treasury companies for purposes of FATCA reporting, in light of updated US IRS guidance . . .
Americas
Text available of TIEA between Ireland and the Bahamas
Irish Tax and Customs on May 1 released the text of a tax information exchange agreement signed by Ireland and the Bahamas. The agreement . . .
Americas
OECD official discusses “double Irish” and US reaction to BEPS with The Irish Independent
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Denmark
Ireland and Denmark sign protocol, text available
Ireland and Denmark, on July 22, signed a protocol to their 1993 tax treaty which would change the method of eliminating double taxation with respect to salaries, wages and similar remuneration. Protocol (PDF, 43KB), Treaty
Europe
Niall Cody to chair of Irish Revenue Commissioners
Niall Cody has been appointed as the new Chairman of the Irish Revenue Commissioners, Minister for Finance, Michael Noonan announced on December 16. Cody will begin work February 1, 2015. See, release.
Europe
Ireland releases guidance on taxation of exchange traded funds
Irish Tax and Customs, on April 16th, released guidance on the tax treatment of investments in exchange traded funds. According to a government . . .
Europe
Ireland issues guidance on foreign tax credit for foreign dividends
The Irish government on January 29 released guidance clarifying a law added in the Finance Act 2013 that provides for an additional foreign tax credit for foreign dividends received . . .
Europe
Ireland to close “double Irish,” but not until 2020 for existing arrangements
Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.
Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
