Contributing Firms:
The Questions

Question 1: The Minister for Finance, Paschal Donohoe T.D., on Thursday January 14th published an Update to Ireland’s 2018 Corporation Tax Roadmap, 'Ireland’s Corporation Tax Roadmap January 2021 Update' outlining further actions that Ireland will be taking as part of international tax reform efforts.

For reference see here.

Can you assess the overall value of the Roadmap, and the nature of its commitments as a useful working document on Ireland’s corporation tax position in the world?

Question 2: Under the Action Plan Commitments (listed in the above), which do you think are most significant?

Question 3: A Review of tax treaties is also underway internationally in the context of the global assessment of corporation tax, such as BEPS and Globe. How extensive is Ireland’s international tax treaty network and how important is it to Ireland’s competitiveness and attraction as a jurisdiction. Do you think further progress in achieving a widening of this is possible in the coming years?

Question 4: Perrigo has now indicated that it will not appeal the Supreme Court ruling on its tax case, covered in recent issues of the Irish Tax Monitor but will now challenge the Revenue’s position to the Tax Appeals Commissioners. Can you comment on this development?

Question 5: In another disputed case in January the Revenue has challenged a ruling by the Tax Appeals Commission (TAC) that a €587 million tax assessment on AbbVie’s acquisition of Allergan, by Revenue acting on a 2020 Finance Bill measure levying a 1% stamp duty on share cancellations which were previously exempt. What are your comments on this?

Tax and Covid-19.

Question 6: The tax function in companies has played an important part in overall financial planning, with, in a considerable number of cases, tax becoming an enhanced part of the cash flow management process. With the second lockdown extending perhaps the earlier hoped-horizons for the duration of the pandemic, what lessons might corporate tax managers take from the experiences of 2020-21?

Question 7:. On December 23rd 2020 the Department of Finance announced a Public Consultation on the workings of the Employment Investment Incentive (EII). What issues do you believe could be addressed in the consultation process?