Category: Ireland

Google loses 6 year battle, must pay tax on remittances made to Google Ireland

Bad news for the world’s favourite search engine. On Tuesday, the Indian tax office gained an upper hand in its six-year-long battle with Google India in a ruling that would set a precedence for some of the other multinational companies. The rift owes its origin to the arrangement and fund… – Continue reading

Revenue receives just 11 tax scheme alerts in six years

Exemptions make the mandatory disclosure regime a joke, says MEP Matt Carthy The Revenue Commissioners have received just 11 reports of potentially abusive tax-avoidance schemes since Ireland made it mandatory in early 2011 for transactions giving “aggressive” tax advantages to be disclosed to authorities. The disclosure by Minister for Finance… – Continue reading

Ireland Updates International Tax Strategy

The Irish Government has published an updated version of its International Tax Strategy, which provides an overview of the steps taken to meet international standards and sets out the Government’s position on global reform efforts. In his foreword to the Tax Strategy paper, Finance Minister Paschal Donohoe said: “In Ireland… – Continue reading

Ireland Seeks Comment on International Tax Strategy Plans

The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January… – Continue reading

Business owners believe Irish tax code ‘is barrier’ to growth

Survey respondents cite high marginal rates and lack of staff reward schemes as negatives More than half of Irish business owners view the State’s tax code as a barrier to growth rather than a support, according to a survey by accounting and professional services firm Deloitte. Respondents cited Ireland’s high… – Continue reading

Change to intellectual property tax write-offs will boost revenues

Move on multinational tax arrangements expected to be announced in the Budget An important change to multinational tax arrangements is expected to be announced in Budget 2018, limiting the tax write-offs big companies can take up front on movements of valuable intellectual property to Ireland. The move could provide a… – Continue reading

E.U., Citing Amazon and Apple, Tells Nations to Collect Tax

BRUSSELS — European competition regulators on Wednesday mounted a push against tax avoidance by Silicon Valley giants, announcing plans to take Ireland to court for failing to collect back taxes from Apple and ordering Luxembourg to claim unpaid taxes from Amazon. The effort, which comes as the European Union considers… – Continue reading

Ireland to be dragged in front of Europe’s highest court for refusing to accept €13billion in Apple back tax

The cash would be enough to fund the entire health service for a year Ireland faces legal action for failing to recover €13billion euros in tax from US tech giant Apple after European competition authorities blasted the country over a sweetheart deal. The European Commission said Ireland had not recouped… – Continue reading

EU divided over radical tax reforms targeting tech giants

The EU is deeply divided over how to increase the tax take from tech giants such as Google, Apple and Amazon, who have recently come under fire for being perceived as not paying their fair share of taxes A controversial set of reforms spearheaded by French president Emmanuel Macron propose… – Continue reading

EU Countries Seek Legislative End-Around on Digital Tech Tax

EU nations led by France and Italy reinforced the need for an “equalization tax” or turnover tax on large internet companies such as Facebook Inc. and Amazon.com Inc., and suggested they would use special legislative procedures to impose one in the event all 28 EU-member countries don’t back the levy…. – Continue reading

Trump’s corporate tax reform plan could neuter Ireland’s advantage

President Trump on Wednesday this week announced a sketchy Republican tax reform plan that covered just 9 pages and he proposed that the headline federal corporate rate should be cut from 35% to 20%. However, there is a risk to Ireland’s low 12.5% corporate tax advantage. The average rate of… – Continue reading

Review of Ireland’s Corporation Tax Regime

Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax… – Continue reading

Donohoe says Ireland opposes ‘equalisation tax’ at EU meeting

The proposals plan to tax giant digital companies on turnover rather than profits EU finance ministers have agreed to step up technical work on harmonising the taxation of the giant digital companies with a view to debating “possible solutions” at their December meeting. The ministerial consensus was a significant setback… – Continue reading

Ireland’s Revenue releases guidelines on requesting Mutual Agreement Procedure assistance

Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: the process through which taxpayers can request assistance from Ireland’s Competent Authority (the Revenue) the possible outcomes resulting from a request… – Continue reading

Ireland Explains Transfer Pricing Documentation Rules

On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading

Irish FinMin Considers Impact Of Brexit On Taxes

As part of the Irish Budgetary process, officials from the Finance Department have published a paper on the implications of Brexit for Ireland’s tax system. The paper was prepared for consideration by the Tax Strategy Group (TSG), an interdepartmental committee chaired by the Finance Department. The papers produced by the… – Continue reading

Ireland, UK and others are offshore ‘conduits’

Computer scientists have worked to uncover the way the Netherlands, the UK, Ireland, Singapore and Switzerland, in particular, are used by multinationals to channel investments onto well-known offshore centres (OFCs). According to the research which was first reported by online journal Quartz, the five countries are used by multinationals to… – Continue reading

France Open To Negotiated Tax Settlement With Google

France intends to appeal against a recent court decision in favor of Google in a major tax avoidance case, but is open to settling the dispute outside of court, a government minister has said. In an interview with Les Echos, Minister of Action and Public Accounts, Gerald Darmanin, said that… – Continue reading

Ibec Publishes Irish Budget Wish List

Business group Ibec has said that the Irish Government must “Brexit proof” its 2018 Budget, improve its foreign direct investment model, and implement a range of tax reforms to compete with the UK. Publishing the group’s pre-Budget submission, Ibec Director of Policy and Public Affairs, Fergal O’Brien said: “The Irish… – Continue reading

Irish Committee Calls For WHT For Overseas Artists

The Irish Parliament’s arts committee has recommended the introduction of a “foreign artists’ withholding tax (WHT) scheme.” The committee has released a report on the Government’s Culture 2025 initiative, which is intended to provide a framework for the development of Irish arts, culture, and heritage over the next eight years…. – Continue reading

Irish FinMin Explains Response To Tax Evasion

Irish Finance Minister Paschal Donohoe has explained the country’s approach to tax evasion during a hearing of the European Parliament’s PANA Committee, and said Ireland is “a strong supporter of international tax reform efforts.” Donohoe was one of several European finance ministers who appeared before the committee on July 11…. – Continue reading

Germany’s Schaeuble Defends Resistance to EU Public Tax Reporting

German Finance Minister Wolfgang Schaeuble defended his opposition to pending European Union legislation that would force large multinational companies to publicly disclose, on a country-by-country basis, their taxes paid and profits. Schauble, who testified before the EU Parliament’s Panama Papers investigative committee July 11, said public reporting of companies’ tax… – Continue reading

Paris wants US corporations to pay fair share of taxes in EU

France wants Brussels to take a tougher stance on American multinationals working inside the European Union (EU) and force them to pay an appropriate amount of tax. “I can tell you that the times we live in are not for the weak,” French Finance Minister, Bruno Le Maire said in… – Continue reading

Ending secret identities is the ‘new frontier’ in fighting tax evasion: OECD’s head of tax Pascal Saint-Amans

Revealing the secret identifies behind shell companies and opaque trusts is the “new frontier” in fighting tax evasion, says the OECD’s head of tax Pascal Saint-Amans. In an exclusive interview with Fairfax Media, Mr Saint-Amans also spoke about the Turnbull government’s tougher domestic laws aimed at cracking down on multinational… – Continue reading

Trump’s tax plan could have rich New Yorkers fleeing for Florida

President Trump has signed three executive orders to spark reviews of tax and financial regulations so taxes on businesses and individuals can be cut. The approach would be different from Trump’s earlier plan, which was criticized as an approach that would mostly benefit higher earners. Michael Zezas, a strategist at… – Continue reading

Noonan: Too Early To Anticipate Tax Performance For 2017

Irish Finance Minister Michael Noonan has said that despite a dip in tax revenues for the first quarter of 2017, “it remains too early to discern any firm trends.” Noonan made the comment during an appearance before parliament’s Budget Oversight Committee. He said that his Department has increased its GDP… – Continue reading

Irish Citizen Denied US Tax Refund On Gambling Winnings

The United States Court of Federal Claims has turned down a claim from an Irish citizen that more than USD5m in US tax withheld on gambling winnings should be refunded under the US-Ireland double tax avoidance treaty. The claim was filed by the plaintiff, John P McManus, after USD5.22m in… – Continue reading

HK’s proposed dedicated tax regime for offshore aircraft leasing

The Hong Kong Government has put forward a proposal to amend its tax laws to establish a dedicated tax regime for aircraft owners/lessors based in Hong Kong and leasing to offshore (including PRC) lessees/airlines (see Timeline / References below) (“Proposed Regime”). Assuming there are no surprises or drafting issues in… – Continue reading

Taxing issues: multinationals still routing profits through Ireland

New Oxfam report indicates Government measures to tackle tax avoidance are failing Multinationals are continuing to route billions of euro in profit to and through Ireland to avoid tax, according to a new report by Oxfam Ireland. The study, which suggests that Government measures aimed at tackling tax avoidance are… – Continue reading

Apple files appeal against the EC’s $14 bn tax bill and accuses the commission of lack of diligence

Apple, which was recently slapped with a $14 bn tax bill for its activities in Ireland has now filed a 14-point appeal against the ruling. The EC had filed a case accusing Ireland of giving “state aid” to Apple. The European Commission (EC) charged Apple on various grounds, including tax… – Continue reading

Irish FM Criticizes EU’s BEPS Response

Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading

Japan, China, Ireland biggest foreign holders of US government bonds

In the latest published data from the US Treasury Department and Federal Reserve Board in respect of November 2016, the value of Treasury Securities held by foreigners was $5.9tn with Japan’s holdings at $1.1tn and China at $1.0tn, followed by Ireland at $275bn. However, some further data show that the… – Continue reading

Ireland Updates Guidance On Tax Ruling Info Exchange

The Irish tax agency has updated its guidance on the automatic exchange of information on tax rulings between EU member states. Changes have been made to the Tax and Duty Manual to set out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376 and the OECD’s framework for the compulsory spontaneous… – Continue reading

If Apple won’t pay tax what hope is there for civilisation?

Multinationals owe responsibility to a wider group than their shareholders As the Apple tax case moves towards the European Union courts, €13 billion has been transferred to Ireland. The implications of the case will effect how multi-national companies implement taxes across Europe. has been accused of “bending the rules” in… – Continue reading

Bermuda – the world’s former ‘No.1 tax haven’ – joins fight against multinationals

Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading

New tax regime for Ukrainian loan participation notes issued on international capital markets

January 2017 – On 21 December 2016, Ukraine’s parliament adopted the Law “On Amendments to the Tax Code of Ukraine Concerning Improvement of the Investment Climate in Ukraine” No. 1797-19. With effect from 1 January 2017, the legislation introduces new rules for the taxation of interest payable by Ukrainian economic… – Continue reading

U.S. tax reform plan “not likely” to badly impact Canada: Expert

WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so… – Continue reading

UK suggests economic body to help tackle tax evasion along Irish border after Brexit

An inter-governmental economic organisation could help tackle tax evasion across the Irish border following Brexit, the UK’s Treasury has suggested. The UK’s only land border with an EU state is in Northern Ireland. Without the European institutions, the Organisation for Economic Co-operation and Development (OECD) could help facilitate dialogue with… – Continue reading