ireland


Ireland Launches Transfer Pricing Consultation

Posted on March 24th, by Global Tax Weekly in International Taxation. No Comments

In Ireland, the Finance Department has launched a consultation (running until April 16) on proposed changes to the transfer pricing regime, focusing on the attribution of profits to branches of non-resident companies.

The proposed changes would extend transfer pricing rules to the taxation of branches in Ireland, in line with the Authorized OECD Approach (AOA).

The AOA seeks to ensure that profits from intra-group dealings are attributed to a permanent establishment, or branch, that would have been earned if the branch or PE were a legally distinct and separate enterprise from the head office. These profits are determined with reference to the profits that would been earned by an unrelated party undertaking the same or similar functions under the same or similar conditions.

For more information on this, and other topical international tax matters, please visit: https://www.cchgroup.com/roles/corporations/international-solutions/research/global-tax-weekly-a-closer-look


Ireland Announces New COVID Measures

Posted on October 30th, by Global Tax Weekly in Business. No Comments

In Ireland, which is currently stepping back up the COVID restriction ladder, the Government announced changes to the Employment Wage Subsidy Scheme (EWSS) and the COVID Restrictions Support Scheme (CRSS).

EWSS has been in place since September 1, 2020. EWSS provides a flat-rate subsidy to qualifying employers based on the number of paid and eligible employees on the employer’s payroll. The employer must have tax clearance to be eligible to join the EWSS and remain “tax clear” in order to receive the subsidy.

The Government said that, broadly, the EWSS rates will be aligned with the rates of payment available under the Pandemic Unemployment Payment, up to EUR350 per week, effective from the next payroll date after October 19. The maximum weekly subsidy rate per employee was previously EUR203.

For more information on this, and other topical international tax matters, please visit: https://www.cchgroup.com/roles/corporations/international-solutions/research/global-tax-weekly-a-closer-look


Ireland Reduces VAT

Posted on September 11th, by Global Tax Weekly in Sales Tax. No Comments

Ireland has reduced its standard rate of VAT from 23 percent to 21 percent from September 1, 2020, with the reduction to be in place until February 28, 2021.

Commenting on the move, Finance Minister Paschal Donohoe explained that: “This temporary reduction in the standard rate of VAT cuts across a wide range of economic activity and as such there is a broad range of the types of businesses and traders who will benefit. Discretion in relation to the setting of prices charged will remain that of relevant businesses. However, it will help consumer confidence, benefit consumers, and generate economic activity if it was passed on to the final consumer.”

However, Ireland is not the only country making moves in the area recently, with Turkey having temporarily lowered the rate of VAT on the supply of education and training services. Under the … Read More »


EU General Court Overturns Apple Ruling

Posted on July 23rd, by Global Tax Weekly in E-commerce. No Comments

Apple and the Irish Government have been successful in overturning a European Commission decision that two tax rulings granted to the company by the Irish Government were unlawful.

Following an in-depth state aid investigation launched in June 2014, the European Commission concluded that the tax rulings (issued in 1991 and in 2007) “substantially and artificially lowered the tax paid by Apple in Ireland since 1991.” Apple was required to pay back taxes into an escrow account set up by the Irish Government, along with interest, pending the outcome of the Government and Apple’s appeal.

The European Commission had argued that Ireland’s endorsement of Apple’s Irish tax arrangements had enabled Apple to pay less tax than competing companies would be able to pay – that it had granted it a “selective tax advantage”, and that the tax rulings issued by Ireland endorsed an … Read More »


Ireland Extends Temporary Wage Subsidy Scheme

Posted on July 17th, by Global Tax Weekly in Government. No Comments

Ireland’s Revenue department revealed that it would give employers additional time to comply with Temporary Wage Subsidy Scheme compliance checks where they are encountering difficulties responding within the current five day timeframe, according to an announcement from Chartered Accountants Ireland.

Ireland’s COVID-19 wage subsidy scheme has been in place since March 26, 2020, and will be administered by the Irish Revenue until August 31, 2020.

Employers who have received subsidy payments under the TWSS are required to provide documentary evidence to establish that they meet the eligibility criteria, that employees are receiving the correct amount of subsidy, and that the subsidy amount is being correctly identified in employee payslips.

However, in a letter to Chartered Accountants Ireland, Revenue explained that employers experiencing difficulties in preparing information in response to letters issued under the TWSS compliance program can contact Revenue and request additional time.

For … Read More »


Ireland Announces COVID Concessions

Posted on May 14th, by Global Tax Weekly in Sales Tax. No Comments

The Irish Revenue has issued guidance on the tax treatment of the supply of emergency accommodation and the donations of gifts of goods or meals supplied in response to the COVID-19 crisis, outlining the application of the Capital Goods Scheme (CGS) to emergency accommodation. The CGS is a mechanism for regulating the amount of VAT reclaimed over the VAT-life, and aims to ensure that the VAT reclaimed reflects the use to which the property is put over its VAT-life.

Revenue said that, as a concessionary treatment, it will not apply the CGS “big swing” adjustment in cases where the change in the proportion of deductible use is a consequence of a capital good being diverted for use as emergency accommodation.

The guidance also explained the VAT treatment of donations of gifts of goods and meals. Generally, where a business donates goods free … Read More »


Ireland Election Date Approaches

Posted on January 24th, by Global Tax Weekly in Elections. No Comments

As the UK gears up to begin the process of leaving the European Union at the end of the month (the implications of which are still, to be honest, as clear as mud in terms of trade and tax matters), near neighbor Ireland has been keeping busy with its own affairs ahead of the Republic’s planned election, to be held in February.

The election is set to take place on February 8, with Prime Minister Leo Varadkar explaining that this date provides a window to ensure a new government is in place ahead of the next European Council meeting in March.

In a recent speech, Varadkar revealed that the next step in the Brexit process, which is likely to especially impact the Republic due to its location and close relationship with the UK, will be to negotiate a free trade agreement between … Read More »


Irish Budget Prepares For No-Deal Brexit

Posted on September 23rd, by Global Tax Weekly in Budgets. No Comments

In Ireland, on September 11, the Irish Finance Department revealed that given the lack of clarity regarding the timing and format that the UK’s exit will take, and with the Budget just four weeks away, the Government has decided to formulate the Budget on the basis of a disorderly Brexit.

The Irish authorities have reported that they are committed to a budgetary package of EUR2.8bn, EUR2.1bn of which has been pre-committed to spending measures. This leaves about EUR700m for tax-side measures.

The Department said that the Government is taking a “twin-track” approach to the Budget. This involves funding services and making progress on particular policy areas and supporting sectors and regions most exposed to Brexit-related disruption.

Finance Minister Paschal Donohoe explained that: “A no-deal Brexit will have profound implications for Ireland on all levels. These include macroeconomic, trade, and sectoral challenges, both immediately … Read More »


Irish Concerns About OECD Proposals

Posted on August 23rd, by Global Tax Weekly in OECD. No Comments

A report compiled by Irish business association, Ibec, has argued that Ireland may be affected significantly by the OECD’s proposals to modify how taxing rights are allocated among countries.

The OECD is developing new digital tax rules that would be presented for adoption internationally at the end of 2020, which will focus on two central pillars.

First, the OECD will review existing rules that divide up among jurisdictions the right to tax the income of multinational enterprises, including traditional transfer pricing rules and the arm’s length principle. It will look at how these can be modified to take into account the changes that digitalization has brought to the world economy. This will require a re-examination of the so-called “nexus” rules – namely how to determine the connection a business has with a given jurisdiction – and the rules that govern how much … Read More »


Irish SMEs Want Reduction In Capital Gains Tax

Posted on August 19th, by Global Tax Weekly in SMEs. No Comments

Ireland’s Small Firms Association recently argued that better supporting SMEs through the tax system would mitigate the country’s over-reliance on revenues linked to foreign direct investment.

According to SFA, Ireland’s competitiveness is under threat. It therefore argued that the Government needs to take steps to “de-risk our economy from over-reliance on FDI and seize an important opportunity to future-proof our economic model.” It said that the Budget needs to provide certainty to small businesses.

One of SFA’s priorities is a reduction in capital gains tax (CGT). It recommended a reduction in CGT to 20 percent across the board (pointing out that, at 33 percent, Ireland’s CGT rate is one of the highest among developed economies), in order to make investing in a business in Ireland more attractive. It also argued for an increase in the lifetime limit for gains under the CGT … Read More »





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