Contributing Firms:
The Questions

Question 1: A global minimum rate of 15 pc has been mooted. This will only have limited application to a selected number of companies. In this context is there any reason for the 12.5% not to remain the Irish Headline rate going forward, e.g. for SMEs ?


Question 2: What types of companies incorporated in Ireland would be subject to the special 15% rate ?


Question 3: If the Irish 12.5% Headline rate is preserved for most companies, what would be the comparative (i.e. headline rate for most companies) rates between Ireland and the following countries: US, UK, Germany, Netherlands, Luxembourg, France, Switzerland, Cayman Islands ?


Question 4: What kinds of Financial Services companies in Ireland would be subject to the 15% ?


Question 5:With the Debt Warehousing Scheme (and the EWSS – (Employment Wage Subsidy Scheme) extended recently (in June) to the end of December 2021, what is the suggested roadmap for a return to the post Covid operational environment, from a tax administration and compliance point of view, for the estimated 86,000 Irish businesses that are availing of the Debt Warehousing Scheme with an aggregate tax debt of €2.3 billion (Revenue) ?


Question 6: In recent years, the Irish courts have overseen several very significant cross-border restructurings including the Ballantyne Re & Nordic Aviation Capital Schemes of Arrangement and the Weatherford International plc and City Jet DAC restructurings by way of Examinership. The recent examinership exit of Norwegian further demonstrates how Ireland is establishing itself as a leading restructuring destination in Europe. In what ways does (and can) Ireland’s tax system facilitate this as well ?


Question 7:The transposition into Irish law of the Institutions for Occupational Retirement Provision (IORP) II Directive at the end of April brings Ireland into line with the rest of the EU, and it is an event of major significance, as it ushers in important changes that have a bearing on tax planning issues with regard to pensions, such as the derogation that allowed one-person schemes to invest in unregulated markets such as property, and to borrow for the purpose of investment.
What broad implications from a tax perspective is the IOPR Directive likely to have ?