Contributing Firms:
If Simon Harris and his Departmental officials are looking for a series of win-win, uncontroversial, and potentially enhancing reforms for Ireland’s national economic interest the proposals offered across the seven topics in this month’s Tax Monitor, starting with long overdue Section 110 reforms are there for the implementation.
The tax simplification agenda remains front and centre at Irish and EU levels and the panel looks at a number of tax pain points that can be addressed at the national level including a revamp of Schedule 24 rules. The treatment of foreign withholding taxes for section 110 companies is also highlighted as an area for attention to ensure the intended tax neutrality of the regime. The impact of the BEPS Side-by-Side package features, as does the disproportionate tax and compliance burden for Irish SMEs, the latest developments on Transfer Pricing and the increasingly fragmented tax treatment of financial services across the EU.
What opportunities do you see to further enhance and refine Ireland’s Section 110 regime?
What could or might be implications of the side-by-side package for dealmaking and deal structuring in/through Ireland? Do the new rules create obstacles or opportunities for Ireland as a global centre for finance and transactions?
What changes would you suggest be made to Ireland’s transfer pricing rules to reduce the compliance burden on Irish companies? In your response we would encourage you to highlight examples of burden-reducing initiatives from other EU jurisdictions.
While changes, such as the introduction of the foreign dividend participation exemption and the prospective introduction of a branch exemption, simplify the tax system for international companies in Ireland, for those that elect to not avail of these exemption or do not qualify remain reliant on the complex foreign tax credit rules in Schedule 24, TCA 1997. In your view, how can these rules be simplified?
The Committee on Economic and Monetary Affairs (ECON) of the European Parliament recently published a draft report on a coherent tax framework for the EU’s financial sector, describing the taxation of financial services in the EU as ‘highly fragmented’ that creates legal uncertainty, drives market distortions and encourages tax avoidance. In particular the report highlights failures to reform the VAT treatment of financial services and the need to address the distortions caused by the VAT exemption, which it says undermines the objectives of SIU and the Banking Union. Please discuss in the context of Ireland’s continued recognition of the ‘tax sovereignty’ principles embodied in the Lisbon Treaty.
What tax simplification measures would have the greatest impact on reducing the burden faced by Irish SMEs in meeting their tax compliance obligations (including VAT amongst other tax heads)?
Finance Act 2025 introduced changes for Ireland’s Investment Limited Partnerships to help improve Ireland’s offering in the private equity/funds space, including an exemption from dividend withholding tax for ILPs. Have these changes been as effective as you wish and what further changes could be implemented to further enhance the ILP and Ireland’s pitch for PE business?
Section 110: What opportunities do you see to further enhance and refine Ireland's Section 110 regime?
M&A: Side-by-Side package: What could or might be implications of the side-by side package for dealmaking and deal structuring in/through Ireland? Do the new rules create obstacles or opportunities for Ireland as a global centre for finance and transactions?
Transfer Pricing: What changes would you suggest be made to Ireland's transfer pricing rules to reduce the compliance burden on Irish companies? In your response we would encourage you to highlight examples of burden-reducing initiatives from other EU jurisdictions.
Foreign Tax Credit Rules: While changes, such as the introduction of the foreign dividend participation exemption and the prospective introduction of a branch exemption, simplify the tax system for international companies in Ireland, for those that elect to not avail of these exemptions or do not qualify remain reliant on the complex foreign tax credit rules in Schedule 24, TAC 1997. In your view, how can these rules be simplified?
Transfer Pricing: EU: Taxation of Financial Services: The Committee on Economic and Monetary Affairs (ECON) of the European Parliament recently published a draft report on a coherent tax framework for the EU’s financial sector, describing the taxation of financial services in the EU as ‘highly fragmented’ that creates legal uncertainty, drives market distortions and encourages tax avoidance. In particular the report highlights failures to reform the VAT treatment of financial services and the need to address the distortions caused by the VAT exemption, which it says undermines the objectives of SIU and the Banking Union. Please discuss in the context of Ireland’s continued recognition of the ‘tax sovereignty’ principles embodied in the Lisbon Treaty.
Tax Administration - SMEs: What tax simplification measures would have the greatest impact on reducing the burden faced by Irish SMEs in meeting their tax compliance obligations (including VAT amongst other tax heads)?