Contributing Firms:
As debate develops regarding the introduction of an Irish Savings and Investment Account the panel examines contrasting compliance and administrative aspects, looking particularly at the contrasting models of the UK/Canada (the ISA and the TFSA), and Sweden’s Investeringssparkonto (ISK).
With recent changes to the tax treatment of carried interest in Luxembourg the panel looks at the changes, how ‘carry’ is treated currently in Ireland and what changes could be made to help attract greater levels of private equity activity. As Ireland prepares to develop and introduce a Savings & Investment Account (SIA) the panel outlines the key tax characteristics of a well-designed SIA, from a compliance and administrative perspective, taking examples from established regimes in other jurisdictions. Other topics featured include the implications of the ‘Side-by-Side’ deal for Irish headquartered multinationals, the next for eInvoicing, withholding taxes in the aviation sector, a review and outlook of Ireland’s R&D tax credit and the implications of the US Supreme Court’s tariffs ruling.
Luxembourg has recently established a permanent regime for Carried Interest, a topic of particular interest for general partners in private equity, strengthening its attractiveness for front office alternative investment fund activity. By contrast, the UK Government has increased the taxation of private equity general partners in recent Budgets. Can you summarise the main features of the new Luxembourg regime? Can you outline how ‘carried interest’ is treated in Ireland currently and suggest changes that could be made to Ireland’s regime to make it more attractive for private equity?
Administrative simplicity can be one of the most important advantages of the Irish SIA, mooted by the Minister for Finance, on foot of earlier suggestions regarding the improvement of investment opportunities for Irish taxpayers such as the Government’s Funds 2030 Report. What could be some of the key characteristics of a well-designed SIA, from a compliance and administrative perspective? In response please refer to any aspects of other SIA regimes (e.g. Sweden’s and Canada’s) that could be referenced in modelling the Irish SIA.
The Department of Finance recently published its Review of the R&D Tax Credit regime and a new R&D Tax Credit and Innovation Compass which together provide a Review and Outlook on a cornerstone of Ireland’s corporation tax policy since 2004. Can you please discuss the findings and the future options for Ireland to further enhance its support of innovation in the Irish economy?
Please comment on the essential implications of the US Supreme Court’s Feb 20th ruling on tariffs, from an Irish and EU trade perspective as the White House seeks alternative remedies, as the ruling is of such a fundamental nature.
What are the implications of the ‘Side-by-Side’ deal for Irish headquartered multinationals?
The introduction of e-invoicing, (the automated, secure exchange of invoice data in a structured, machine-readable format (e.g., XML) between supplier and buyer), forms a key part of the EU ViDA Directive. As part of this the Irish Revenue Commissioners have confirmed that large corporates will be required to issue e-invoices from 1st November 2028. What steps should in-scope companies now be taking to meet the new obligations?
The imposition of withholding taxes on aircraft and engine leases was the subject of a recent policy statement from the Aviation Working Group, the global body representing major aviation manufacturers, leasing companies and financial institutions. It pointed to the negative implications of WHT being imposed on leases for both airlines and lessors. How might these be mitigated against?
The tax treatment of Carried Interest in Private Equity: Luxembourg has recently established a permanent regime for Carried Interest, a topic of particular interest for general partners in private equity, strengthening its attractiveness for front office alternative investment fund activity. By contrast, the UK Government has increased the taxation of private equity general partners in recent Budgets. Can you summarise the main features of the new Luxembourg regime? Can you outline how 'carried interest' is treated in Ireland currently and suggest changes that could be made to Ireland’s regime to make it more attractive for private equity?".
Tax design of SIAs: Administrative simplicity can be one of the most important advantages of the Irish SIA, mooted by the Minister for Finance, on foot of earlier suggestions regarding the improvement of investment opportunities for Irish taxpayers such as the Government’s Funds 2030 Report. What could be some of the key characteristics of a well-designed SIA, from a compliance and administrative perspective? In response please refer to any aspects of other SIA regimes (e.g. Sweden’s and Canada’s) that could be referenced in modelling the Irish SIA.
Pillar Two / Global Minimum Tax – The ‘Side-by-Side’ Deal: What are the implications of the ‘Side-by-Side’ deal for Irish headquartered multinationals?
E-Invoicing: The introduction of e-invoicing, (the automated, secure exchange of invoice data in a structured, machine-readable format (e.g., XML) between supplier and buyer), forms a key part of the the EU ViDA Directive. As part of this the Irish Revenue Commissioners have confirmed that large corporates will be required to issue e-invoices from 1st November 2028. What steps should in-scope companies now be taking to meet the new obligations?
Aviation finance and WHT: The imposition of withholding taxes on aircraft and engine leases was the subject of a recent policy statement from the Aviation Working Group, the global body representing major aviation manufacturers, leasing companies and financial institutions. It pointed to the negative implications of WHT being imposed on leases for both airlines and lessors. How might these be mitigated against?
The US Supreme Court ruling on tariffs: Please comment on the essential implications of the US Supreme Court's Feb 20th ruling on tariffs, from an Irish and EU trade perspective as the White House seeks alternative remedies, as the ruling is of such a fundamental nature.
R&D Tax Credit – Review & Outlook: The Department of Finance recently published its Review of the R&D Tax Credit regime and a new R&D Tax Credit and Innovation Compass which together provide a Review and Outlook on a cornerstone of Ireland’s corporation tax policy since 2004. Can you please discuss the findings and the future options for Ireland to further enhance its support of innovation in the Irish economy?