Ireland resolved 9 mutual agreement procedure (MAP) cases with other nations in 2014, leaving an inventory of 22 unresolved MAP cases by the end of that year, Irish Revenue said in a report, released on November 9.
The report, titled The Role of Ireland’s Competent Authority, also revealed that seven new MAP cases were added to inventory during 2014.
While Ireland does not currently have a formal advance pricing agreement (APA) program, Irish Revenue will enter into bilateral APAs with treaty partners, the report said. Ireland is considering adopting a formal program, as recommended by the outcome of action 14 the OECD/G20 base erosion profit shifting project, the report said.
There are currently eight bilateral APAs in force in Ireland, and Irish Revenue has, to date, received six new requests for APAs in 2015, the report said.
The report also said that over the past 18 months, Ireland has expanded its competent authority personnel. Until the fourth quarter of 2013, Ireland’s competent authority function was undertaken by a single principal officer, who relied on Irish Revenue’s Large Cases Division and the Statistics and Economic Research team for support.
By the second quarter of 2015, the competent authority team included a principal officer, three assistant principals, and one administrative officer, the report said. Moreover, Ireland expects, by the end of 2015, to add two more assistant principal officers and two more administrative officers to the team.
Ireland is committed to resolving international tax disputes and is willing to enter into a multilateral instrument with other countries to adopt mandatory binding arbitration, the report said.
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