Contributing Firms:
The global minimum tax system received a short-term boost in early January with agreement reached by jurisdictions in the Inclusive Framework to the ‘side-by-side’ system. While the deal offers short-term certainty for corporate tax planning, the changes call into question the longer term prospects for Pillar Two.
The Department of Finance’s proposals to revamp Ireland’s complex taxation of interest regime with panelists taking the view that aspects of the proposals are wide of the mark when it comes to improving and simplifying the regime for taxpayers. 2025 was a tumultuous year for the BEPS Pillar Two, and the panel review the key developments and where the rules now stand while they also outline what the taxation priorities should be under Ireland’s EU Presidency in H2 2026. The new guidance on the territorial scope of VAT groups features as does the public consultation on eWHT as well as does the latest developments in the area of tax technology.
The Department of Finance has published a ‘Strawman’ proposal setting out an alternative approach to the taxation and deductibility of interest in Ireland. What is your assessment of the proposal? Does it sufficiently address stakeholders’ primary concerns? The Department in the Feedback Statement identified these as including: “(1) The alignment of tax treatment between trading and passive interest income for income tax and corporation tax purposes, including a move to an accruals basis of assessment for interest income under Case III and Case IV of Schedule D; (2) The introduction of a renewed and simplified test for the deductibility of interest, which would align the treatment between trading and passive interest expenses for the purposes of computing corporation tax. (3) The widening of the scope of interest deductibility to include ‘interest equivalent’ amounts, which are economically equivalent to interest expenses”.
This past year - 2025 - has been a watershed year for the OECD’s BEPS project, and some might say even a terminal year. Can you summarise the main developments providing your assessment of its prospects in 2026, and what it might mean for large Irish corporate taxpayers in particular?
From an EU taxation perspective, what would you like to see Ireland prioritising in 2026, with its upcoming EU Presidency in the second half of 2026 in mind?
The Department of Finance and the Revenue Commissioners have launched a joint public consultation on eWHT. What are the key aspects of the proposed changes? What impact will they have on taxpayers? Please refer to any points you or your firm have made in response to the consultation.
The Revenue Commissioners have released new guidance on the territorial scope of VAT groups. Can you review the most relevant points for taxpayers of new guidance and any implications for taxpayers?
Would you comment on significant developments in the area of tax technology in 2025, focusing on applications of AI in applied tax practice in particular?
BEPS – review and outlook: This past year - 2025 - has been a watershed year for the OECD’s BEPS project, and some might say even a terminal year. Can you summarise the main developments providing your assessment of its prospects in 2026, and what it might mean for large Irish corporate taxpayers in particular.
Ireland's EU Presidency & taxation at an EU level : From an EU taxation perspective, what would you like to see Ireland prioritising in 2026, with its upcoming EU Presidency in the second half of 2026 in mind?
The taxation of interest in Ireland: The Department of Finance has published a 'Strawman' proposal setting out an alternative approach to the taxation and deductibility of interest in Ireland. The Department in the Feedback Statement identified these as including: "(1) The alignment of tax treatment between trading and passive interest income for income tax and corporation tax purposes, including a move to an accruals basis of assessment for interest income under Case III and Case IV of Schedule D; (2) The introduction of a renewed and simplified test for the deductibility of interest, which would align the treatment between trading and passive interest expenses for the purposes of computing corporation tax. (3) The widening of the scope of interest deductibility to include ‘interest equivalent’ amounts, which are economically equivalent to interest expenses".
What is your assessment of the proposal? Does it sufficiently address stakeholders’ primary concerns?
Withholding Tax: The Department of Finance and the Revenue Commissioners have launched a joint public consultation on eWHT. What are the key aspects of the proposed changes? What impact will they have on taxpayers? Please refer to any points you or your firm have made in response to the consultation.
VAT: The Revenue Commissioners have released new guidance on the territorial scope of VAT groups. Can you review the most relevant points for taxpayers of new guidance and any implications for taxpayers?
Tax Technology: Would you comment on significant developments in the area of tax technology in 2025, focussing on applications of AI in applied tax practice in particular?