Ireland reevaluating tax treaty policy

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 international tax discussions. Ireland aims to formulate the best approach to negotiating tax treaties with developing countries and generally facilitate business and economic opportunities in the country.

The Department of Finance notes that the purpose of tax treaties has evolved and expanded to include anti-abuse measures under the OECD base erosion and profit shifting (BEPS) project. With this in mind, the consultation asks how Ireland can optimize its tax treaty priorities in the context of OECD reforms.

Another question the country is looking into is whether it should approach tax treaties with developing countries differently and, if so, how. It asks which international best practices it should follow and whether it should more greatly emphasize the UN model tax treaty in this respect.

Regarding tax treaties with developing countries, the consultation asks whether Ireland should adopt standard positions on certain issues – naming specifically, as an example, the issue of source taxation.

More generally, Ireland is interested in the gaps in its current tax treaty policies and network as a framework for future negotiations. It is interested in hearing about how tax treaty policy could better cater to Ireland’s economic environment and what business sectors might not be well served currently.

Comments on the consultation are due by May 7.

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