Contributing Firms:
In this issue
Fundamental changes in the taxation of financial services ushered in in Finance Act ‘23
As if the roll-out of change springing from the OECD’S BEPS process were not enough to disturb the status quo for financial services industry tax, a series of not unrelated developments are happening in parallel, a number of them springing from the Finance Act, enacted in late December. One of these are changes in the approach of Revenue to the taxation of aircraft leasing, and members of the Panel in this month’s issue address these. The Roundtable shows that the scope of change is wider than aircraft leasing, and indeed leasing companies in general; it encompasses the application of interest deductibility rules and the new concept of ‘qualifying finance companies’ introduced in the Act. The Roundtable also provides overviews in other key and linked areas, such as the introduction of new ‘qualifying finance companies’, the implications of a move to a territorial tax system, and reverberations in the areas of investment (for example ETFs, which are treated unfavourably for Irish-resident investors). Other issues coming into scope will be the definition of ‘trading’ in Irish tax law, which has implications for funds, insurance and the tax treatment of many other Irish corporate structures.structures.