Contributing Firms:
The Questions

Question 1:

The EU has commenced a consultation period on the efficacy and application of VAT as it applies in the financial and the insurance sectors.
What can be expected of this, and will there be change.?

(For Reference see here.)

Question 2: How useful has the Revenue briefings on Brexit been, and what are the omissions have there been that could usefully be clarified between now and the end of the year?

(For Reference see here.)

Question 3: The Government Published (13th November) the Interdepartmental Pensions Reform & Taxation Group 2020, which it was obliged to to on foot of The Roadmap for Pensions Reform 2018-2023 which allocated a number of Actions to the Interdepartmental Pensions Reform & Taxation Group (IDPRTG) for consideration. These relate to three general areas: proposals aimed at simplifying and harmonising the supplementary pension landscape;an assessment of the cost of State support for pension savings;and a review of the Approved Retirement Fund (ARF).

Please comment on the taxation implications of the report for companies and directors, including reference to the treatment of ARFs?

(For Reference see here.)

Question 4: BEPS 2.0 Process

The Consultation will end on December 2020, and after that the findings are likely to further slip into the discussion stream around the world. What are your thoughts on latest thinking- e.g. in relation to the Pillar 1, and Pillar 2 areas, and the idea that it might coalesce around a benchmark tax rate that is close to Ireland’s headline rate of corporation tax.

Question 5:
What would be the likely tax consequences for Ireland of a Biden Presidency in the United States, particularly referencing corporation tax in the coming four years? (With or without a Democrat Party majority in the Senate – an issue that ‘s not likely to be decided until runoff election results in January).

Question 6: Perrigo. What possible consequences could arise for corporation tax from the 155 page Perrigo judgement issued in the High Court this month? In particular, might it have consequences for pharma companies and other companies in the business of trading in intellectual, or other, capital product revenue streams. Are there protective measures that companies should consider in the context, for example revision of their object of trade in their memoranda of establishment, for example in relation to defining capital trading activity as a ‘badge’ of their trade.

Question 7:. With Mandatory disclosure provisions under DAC 6 set to be implemented on January, 1st, following the 6 month Covid-19 deferral, what final checklist of items should taxpayers have considered, (including clarificatory references in the Finance Bill 2020).