Contributing Firms:
The Questions

Question 1:BEPS: Mid-Year Review : What have been the principal ‘Pillar 1 & Pillar 2’ developments in the first half of 2022 and do you envisage the timeline for the rules to come into force changing?

Question 2: Debt vs Equity finance : Can you please outline the tax advantages of using debt finance over equity finance? How is the EU's DEBRA directive attempting to level the playing field in this regard?.

Question 3: BEPS & International Financial Services : BEPS: What are the potential tax implications for International Banking in Ireland as a result of the changes being brought about by the OECD’s BEPS project?

Question 4: Tax Appeals Commission: Tax Appeals Commission: Can you please comment on the most noteworthy determinations made by the Tax Appeals Commission during the second quarter of 2022?

Question 5: Technology : ‘Tax Tech’: What in your view are the main tax tech issues that will need to be addressed by large corporate CFOs in Ireland in the coming years?

Question 6: Ireland's Tax Treaty Policy: The Department of Finance recently outlined its Tax Treaty priorities and plans in a policy published on 27th June. Ireland's longstanding tax treaty policy has been to expand, maintain and enhance its tax treaty network, in order to remove barriers and facilitate trade and investment opportunities between Ireland and partner countries. Can you please explain how Double Taxation Treaties can encourage trade and activity between countries and comment on Ireland's Tax Treaty Policy Statement? (You can view the Statement here.)

Question 7: Wildcard : Optional ‘Wildcard’ Question