Factsheets

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.

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.