Insights

Prior to Finance Act 2021, a company not resident in Ireland for corporate tax purposes was not within the charge to Irish corporation tax unless it was carrying on a trade in Ireland through a branch or an agency.

As required by the EU Anti-Tax Avoidance Directive (ATAD), Finance Act 2019 introduced wide ranging anti-hybrid mismatch rules into Irish domestic tax legislation. These provisions apply in respect of all payments made or arising on or after 1 January 2020. These rules present some of the most complex tax provisions introduced in recent times introducing unique definitions, terminology and concepts not previously referenced under any other piece of Irish tax legislation.

Irish transfer pricing rules apply to arrangements entered into between associated persons (companies) on or after 1 July 2010, involving the supply or acquisition of goods, services, money or intangible assets. Our transfer pricing guide provides an overview of the Irish Transfer Pricing rules.