Contributing Firms:
In an assessment of the Department of Finance’s Strawman Proposal on the introduction of a participation exemption for foreign dividends in this month’s Irish Tax Monitor BDO’s Angela Fleming says, while improvements could be made, the proposal would be a significant move for simplifying Ireland’s corporate tax regime.
In this month’s roundtable the panel looks at the potential impact of BEPS Pillar Two rule on the investment funds industry in light of the extension of rules to standalone entities under Ireland’s domestic top up tax. New guidelines issued by Revenue on the VAT treatment of negotiation services in respect of financial services, with the panel outlining the conditions to be satisfied to fall within a VAT exemption. Building on the commentary on tax treatment changes for Aircraft Leasing activity in Ireland in last month’s Irish Tax Monitor, this month the panel outlines industry adaptations to the new rules. Noteworthy determinations by the Tax Appeals Commission in the opening quarter feature royalty withholding taxes, ‘expenses of management’ and ‘wide reaching’ information requests. A guidance Update to the recently introduced ERR also features while the changes in taxation of share options when exercised, and what companies need to do to meet the new rules is explained.
What is the potential impact of the Pillar Two rules on the investment funds industry?
The Revenue Commissioners has introduced new guidelines on the VAT treatment of negotiation services in respect of financial services. Can you outline the changes and implications for affected taxpayers?
Can you comment on noteworthy determinations from the Tax Appeals Commission from the first quarter of 2024?
Given the changes to the corporation tax treatment of leases (see March 2024 Irish Tax Monitor), how are Irish-based aircraft leasing companies adapting to the changes?
The Finance Act changes the way tax is collected from the exercise of share options, which is also the subject of a recent update from the Revenue Commissioners. Can you explain the changes and steps that should be taken to meet the new requirements?
The recently introduced Enhanced Reporting Requirements has been the subject of a recent guidance update. Can you outline the new guidance?
Deloitte’s Tatiana Kelly presents a clear and focused list of tax measures that would directly impact the wellbeing of Ireland’s SMEs. whom, latest 2024 data show, account for 99.8% of all enterprises, and employ 7 in every 10 Irish workers. She lists a key tax measures that could not only help Ireland’s SMEs to stay afloat but prosper as part of a ‘whole of government approach’.
On 5 April, Minister for Finance Michael McGath TD published a first feedback statement on the development of a participation exemption for foreign dividends to the Irish Corporation Tax system. The feedback statement includes a ‘strawman proposal’ that sets out a hypothetical example for how a participation exemption for foreign dividends might work in Ireland, writes BDO’s Angela Fleming, who says while there are aspects that could be improved upon, the current proposal ‘would be a significant step forward in the simplification of the Irish corporate tax system’.
BEPS and investment funds: What is the potential impact of the Pillar Two rules on the investment funds industry?
VAT treatment of negotiation services: The Revenue Commissioners has introduced new guidelines on the VAT treatment of negotiation services in respect of financial services. Can you outline the changes and implications for affected taxpayers?
Tax Appeals Commission: Can you comment on noteworthy determinations from the Tax Appeals Commission from the first quarter of 2024?
Aircraft Leasing: Given the changes to the corporation tax treatment of leases (see March 2024 Irish Tax Monitor), how are Irish-based aircraft leasing companies adapting to the changes?
Share options changes: The Finance Act changes the way tax is collected from the exercise of share options, which is also the subject of a recent update from the Revenue Commissioners. Can you explain the changes and steps that should be taken to meet the new requirements?
Enhanced Reporting Requirements - ERR: The recently introduced Enhanced Reporting Requirements has been the subject of a recent guidance update. Can you outline the new guidance? In your experience, are your clients experiencing any major pain points meeting the new requirements?