Looking ahead at the Finance Bill the panel also calls for a reduction in CGT, continued improvements to the R&D regime, and other tax changes to encourage and facilitate retail investor activity in tandem with the introduction of an Irish Savings and Investment Account.
With preparations underway for the next Budget the panel identify a number of areas that could be updated to improve the environment for international business in Ireland, including the extension of the participation exemption to foreign branch income. BDO’s Michelle Adams also calls for continued enhancements of the R&D tax credit, tax changes to boost retail investor numbers and a reduction of Ireland’s CGT rate, which at 33% is far above the EU average of c. 20%.
On the R&D regime McCann FitzGerald’s Deirdre Barnicle calls for enhancements including the removal of the restrictions on outsourced related party R&D, the cap on subcontracting, and the cap on the application of the credit to the universities and third level institutions.
Ogier’s John Perry shares his insights on the work of the Tax Appeals Commission and says determinations published in the first quarter of 2026 ‘underscores the Commission’s broader approach as a tribunal that prioritises evidential clarity, statutory certainty and procedural compliance over equitable considerations, with determinations reflecting a predictable but exacting framework in which well-documented and technically supported positions are essential to successfully challenging Revenue assessments.’
On tariffs BDO’s Carol Lynch says that the 20th May agreement between the European Parliament and Member States should enable the EU-US deal agreed last year to enter into force ahead of a deadline that could trigger further tariffs – although she adds even with this deal coming into force it is unlikely to eliminate uncertainty and cost pressures for companies in relation to tariffs.
Ogier’s Arthur Gaskin says uncertainty needs to be ‘treated as a standing operating condition, not a passing phase’ by companies affected by the ongoing tariff uncertainty between the US and EU. The trade deal between the EU and the US has come under increasing question amidst threats of new tariffs from the US and counter-threats from the EU. Gaskin says this ‘reflects a deeper structural shift rather than a temporary diplomatic impasse’ in EU-US trade relations.
He says that a key lesson for companies is ‘the need to move away from high-level country exposure analysis and toward product-specific assessment’ with tariff risks increasingly turning on individual products, sector carve-outs, and overlapping regimes. ‘This fragmentation means that two products shipped by the same company can face dramatically different trade outcomes. Conducting granular audits of tariff exposure by product line is therefore essential for sound pricing, sourcing, and investment decisions.’
Also on the topic of tariff uncertainties McCann FitzGerald’s Barnicle agrees these are no passing fad: ‘what emerges as evident from the chaos, is that external market uncertainty will remain a prominent feature for businesses trading with the US, as long as the strategy of US protectionism is pursued’. But, she adds, Brexit has given Ireland unique experience living in the crossfire of trade disputes. She says companies need to be proactive in relation to tariff changes as internal hesitancy ‘may harm businesses as much as any tariff itself’ and advises companies conduct scenario modelling to understand how to insulate themselves by diversifying their supply chain where possible”.
Ireland’s corporation tax receipts were strong for April, up over 8% on a year-by-year basis and while the strong early year performance is to be welcomed, Ogier’s Edwina Hilton emphasises that Q1 and April ‘are not typically significant corporation tax months’ with the major payment dates still to come. ‘While these figures provide a positive early signal, in a period of continued global uncertainty... we would caution against drawing definitive conclusions about the full-year outlook as the underlying trends will only become clearer as the year proceeds’ she says.
Deirdre Barnicle notes the Irish Fiscal Advisory Council’s repeated warnings on the Irish Exchequer’s ‘critical dependence on corporation tax receipts from a small number of companies.’ However, she notes a positive change revealed by Revenue analysis that points to a small broadening of the corporation tax base with net CT receipts from SMEs growing by 15% in 2025.
This article appeared in the May 2026 edition of the Irish Tax Monitor.
