Insights

On 22nd March 2021, the EU Council introduced "DAC7”, or the 7th Directive (2011/16/EU), on Administrative Cooperation, which enables EU Member States to address some of the perceived negative aspects of the digital economy, by extending the scope of existing exchange of information provisions between Member States, and thus ensuring greater transparency on cross border transactions.

The Forum on Tax Administration, a member group of the OECD/G20 Inclusive Framework on BEPS (Base Erosion and Profit Shifting), along with other OECD task forces, published a guide to Multilateral Mutual Agreement Procedures multilateral (MAPs) and Advance Pricing Arrangements (APAs). This guide is abbreviated as the ‘MoMA’.

The European Parliament has published its approval of the European Commission’s draft proposal for Anti-Tax Avoidance Directive III (ATAD III) with recommended amendments.

The European Commission held a public consultation in respect of a new proposed corporate tax system referred to as Business in Europe: Framework for Income Taxation (“BEFIT”). According to the Commission, the initiative aims to introduce a single corporate tax rulebook for the EU, based on a common tax base and allocation of taxable profits to Member States based on a pre-defined formula. Once allocated, the taxable profits would be subject to the corporate income tax rates of the relevant Member States.

The European Commission recently issued a proposal to amend the Directive on Administrative Cooperation (DAC) in the form of DAC8. The proposal extends the reporting obligations under the Directive to cover income or revenue streams generated from crypto-assets.

Ireland represents a strategic European base due to our pro-business, low corporate tax environment and skilled workforce. As a result of these and other factors, more than 1,600 multinational companies have chosen Ireland as their investment platform.

Residential Zoned Land Tax (RZLT) was introduced by Finance Act 2021 as part of the Government’s Housing for All plan. RZLT is intended to act as a stimulus to induce residential development on land earmarked by local authorities as suitably serviced and zoned wholly or partly for residential purposes.

The Irish Revenue (“Revenue”) published updates to their tax and duty manual (“TDM”) containing guidelines for correlative adjustment (“CA”) claims under Ireland’s double tax treaty network. Read summary of the Revenue guidelines.

Finance Bill 2022 (“the Bill”) was published on 20 October and includes the legislative provisions implementing the tax measures announced as part of Budget 2023, as well as introducing new measures and amendments to the Irish tax code. In this article, we outline the key changes which may impact international groups and companies operating in Ireland.

The European Commission recently published a proposal for a new EU Directive creating a debt-equity bias reduction allowance (‘DEBRA’) and further limitation of the deductibility of interest for corporate tax purposes. This initiative is part of the “EU strategy on business taxation”.

In recent years, there has been a global movement towards increased tax transparency, particularly following a number of high profile financial crises and scandals. Coupled with the growth in the digital economy as well as crypto-assets and e-money in particular, the European Union (EU) has proposed a new Directive on Administrative Cooperation (DAC) known as “DAC8”.

The Irish Transfer Pricing (TP) rules introduced by Finance Act (FA) 2019 apply to Accounting Periods starting on or after 1 January 2020.