Legislation governing hybrid mismatches is due to be introduced in the Finance Act 2019, and while it is hoped that when enacting these rules that Ireland does not go beyond what is necessary to implement the Directive, as it has the capability to interfere with our international competitiveness.
It is also incumbent on taxpaying firms to be prepared for the changes inrtoduced in advance of the implementation date of January 1st 2020.
The growth of Ireland’s international financial services sector will depend in part on personal effective tax rates, according to Cormac Kelleher of Mazars, who is reflecting an increasing sentiment shared across the tax advisory community. This in turn reflects increasing tax competition in the corporate area and noises from politicians across the Irish Sea about personal taxation of all kinds in an effort to boost UK competitiveness in a post Brexit environment.
The Special Assignee Relief Programme (SARP) regime, has been the vehicle used to soften the effective tax rate for relocating employees in an FDI context in Ireland, and this month’s tax Monitor references the SARP consultation process that is ongoing. Regarding potential Income Tax issues in the Budget, the SARP is an essential part of the tax system - in terms of continuing to attract senior personnel to Ireland, says Susan Carroll, Manager, Deloitte.