Contributing Firms:
Potential changes to the default position on confidentiality in the tax appeals system risks making Ireland an EU outlier in the tax appeals area. The proposals and their potential impact are analysed, as are the latest developments in the EU’s efforts on simplification in the areas of WHT and administrative cooperation.
Proposals to make amendments to rules around Ireland’s tax appeals system are analysed in this month’s roundtable, with the proposals risking making Ireland an outlier amongst its European peers when it comes to the confidentiality of taxpayers making an appeal. We also look at proposed changes at EU level including the pros and cons of how the proposed introduction of an exemption from withholding tax on all cross-border payments of dividends, interest, and royalties between companies in the EU would work. How this could specifically affect the domicile choices for investment fund managers also features. Still at EU level, the consolidation and streamlining of the existing, sprawling, DAC framework is also analysed with the work to combine DAC1 to DAC9 into a single instrument a key priority under the Irish Presidency of the Council of the European Union.
Proposed amendments to the current system for tax appeals have been criticised by the Irish Tax Institute which warned the moves would make Ireland ‘a European outlier’ in the area. Currently appeals and determinations are invariably anonymous and redacted but proposed changes would give Appeal Commissioners the discretion to decide if a tax appeal hearing should be held in public or in private and limit the redaction of TAC determinations to cases where there are “special and limited circumstances”. What are your views on the proposed amendments contained in the General Scheme of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2025?
The corporation tax receipts for June 2026 are expected to include some of the first returns and payments from Pillar Two in-scope firms. With the actual June Exchequer returns due to be published as per normal within the next week from now, can you comment on these in the light of the actual outturn.
The European Commission has made proposals to ‘recast’ the Directive on Administrative Cooperation (DAC) which will bring together the DAC and its eight amendments into a single legal text making it more user-friendly while making changes that will ‘simplify, clarify and enhance the EU legal framework for administrative cooperation in the field of direct taxation.’ It says the changes to DAC will result in compliance cost savings of almost €1 billion. What are the measures in the proposed recast DAC that will have the most meaningful impact in cutting compliance costs? With many of the proposals already implemented in Irish legislation, can you comment on areas where particular attention may need to apply, in light also of the fact that Ireland as EU President of the Council will hold the Presidency in the Second half of 2026.
A headline item in the European Commission’s Omnibus on Direct Taxation is the introduction of an exemption from withholding tax on all cross-border payments of dividends, interest, and royalties between companies in the EU which it says should give EU taxpayers savings and benefits of around €5.3 billion annually. Please outline the current inefficiencies in this area and whether the current proposals are likely to achieve their goal of ‘boosting financing, encouraging investment and enhancing competitiveness’ in the Single Market.
From an Irish funds industry perspective are the proposed changes around WHT for dividends, interest and royalties likely to have any influence on the investment managers’ choice of domicile and legal structure for their European fund offerings?.
Tax Appeals Commission: Proposed amendments to the current system for tax appeals have been criticised by the Irish Tax Institute which warned the moves would make Ireland 'a European outlier' in the area. Currently appeals and determinations are invariably anonymous and redacted but proposed changes would give Appeal Commissioners the discretion to decide if a tax appeal hearing should be held in public or in private and limit the redaction of TAC determinations to cases where there are “special and limited circumstances”. What are your views on the proposed amendments contained in the General Scheme of the Finance (Tax Appeals and Fiscal Responsibility) Bill 2025?
Exchequer Returns - June 2026: The corporation tax receipts for June 2026 are expected to include some of the first returns and payments from Pillar Two in-scope firms. With the actual June Exchequer returns due to be published as per normal within the next week from now, can you comment on these in the light of the actual outturn.
DAC: The European Commission has made proposals to 'recast' the Directive on Administrative Cooperation (DAC) which will bring together the DAC and its eight amendments into a single legal text making it more user-friendly while making changes that will 'simplify, clarify and enhance the EU legal framework for administrative cooperation in the field of direct taxation.' It says the changes to DAC will result in compliance cost savings of almost €1 billion. What are the measures in the proposed recast DAC that will have the most meaningful impact in cutting compliance costs? With many of the proposals already implemented in Irish legislation, can you comment on areas where particular attention may need to apply, in light also of the fact that Ireland as EU President of the Council will hold the Presidency in the Second half of 2026
EU Witholding Tax: A headline item in the European Commission's Omnibus on Direct Taxation is the introduction of an exemption from withholding tax on all cross-border payments of dividends, interest, and royalties between companies in the EU which it says should give EU taxpayers savings and benefits of around €5.3 billion annually. Please outline the current inefficiencies in this area and whether the current proposals are likely to achieve their goal of ‘boosting financing, encouraging investment and enhancing competitiveness’ in the Single Market.
Witholding Tax Changes: From an Irish funds industry perspective are the proposed changes around WHT for dividends, interest and royalties likely to have any influence on the investment managers' choice of domicile and legal structure for their European fund offerings?