Contributing Firms:
Enhancing the rules around the taxation of interest is likely to carried out through targetted changes in the Finance Bill, rather than a wholesale reform of the regime, with hopes high that changes to the current framework can deliver the simpler, less burdensome regime being aimed for. Elsewhere, as Ireland’s funds industry reaches a tokenisation milestone, clarity on the taxation of tokenised assets is seen as key to building on recent wins in the area.
The reform of Ireland’s taxation regime for interest is a key agenda topic for Irish corporates and the recently publish feedback on the 2025 strawman has shown dissatisfaction amongst stakeholders. The panel looks at the latest developments on this reform possible changes that could be included in the Finance Bill to achieve many goals of the reform. The panel also analyse the Retail Investment Roadmap and the format of the PIA, ahead of further detail to be released in the Budget 2027. With an updating of the 1907 Limited Partnership legislation in train the panel look at how they could be made more attractive from a taxation perspective while considerations for legislation and tax treatment of tokenised assets also feature. Other topics analysed include the taxation elements of the new Ireland for Finance Strategy as well as upcoming issues for corporate tax functions, including Country-by-country reporting.
In their joint response, made public in August, to the Department of Finance’s ‘Feedback Statement for Phase One of Reform of Ireland’s Taxation Regime for Interest’, the Irish-headquartered MNEs Johnson Controls, Eaton Corporation and Medtronic wrote ‘the Feedback Statement is very disappointing from a business community perspective. It is unclear what tangible benefits the proposed measures would bring to taxpayers, aside from potentially addressing some very specific or limited circumstances.’ How have plans to reform Ireland’s taxation regime for interest evolved in 2026 and what are the key changes that would result in ‘tangible benefits’ for Irish corporate taxpayers?
The recent launch of tokenised share classes of Irish-domiciled Money Market Funds demonstrates the potential for increasing use of tokenisation in the funds and the broader financial services industry. This comes as the Government has already committed to legislative changes to support tokenisation of investment funds in particular. In your view, what are the potential tax considerations, if any, of updating legislation to support tokenisation of funds, and indeed the use of tokenisation in other sectors?
The Department of Finance is due to publish a roadmap on retail investment in the coming days. Can you please comment on the tax elements contained in the roadmap?
For multinational businesses with a December year end, the first public country-by-country (CbC) reports are due by 31 December 2026. Can you outline what businesses affected by the pCbC reporting regime should be doing now as the deadline approaches and what are the key requirements that will need to be met?
The Department of Enterprise, Tourism and Employment have committed to updating the 1907 Limited Partnership and have recently conducted a public consultation on reform of the framework. Are there tax aspects that could also be considered as part of the reforms to enhance the 1907 LP?
With Budget 2027 to be announced on 6 October, which measures will be most consequential for Ireland’s financial services sector?
The Department of Finance launched the latest Ireland for Finance strategy on 25th August. The strategy outlines the planned (and in some cases, ongoing) tax reforms in the areas of R&D, taxation on interest (see Question 3) and Section 110. In your view, what other aspects of Ireland’s tax regime, if reformed, could support the goals outlined in the IFF strategy - ‘to incentivise entrepreneurship, fostering innovation, and enhancing the competitiveness of our tax framework for inward investment’?
What are key challenges facing the corporate tax manager in the coming 12-18 months? What steps can be taken to prepare to meet these challenges?
How can Ireland remain competitive as other jurisdictions seek to attract international financial services activity?
Retail Investment: The Department of Finance is due to publish a roadmap on retail investment in the coming days. Can you please comment on the tax elements contained in the roadmap?
Tokenisation: The recent launch of tokenised share classes of Irish-domiciled Money Market Funds demonstrates the potential for increasing use of tokenisation in the funds and the broader financial services industry. This comes as the Government has already committed to legislative changes to support tokenisation of investment funds in particular. In your view, what are the potential tax considerations, if any, of updating legislation to support tokenisation of funds, and indeed the use of tokenisation in other sectors?.
Taxation of Interest: In their joint response, made public in August, to the Department of Finance’s ‘Feedback Statement for Phase One of Reform of Ireland’s Taxation Regime for Interest’, the Irish-headquartered MNEs Johnson Controls, Eaton Corporation and Medtronic wrote ‘the Feedback Statement is very disappointing from a business community perspective. It is unclear what tangible benefits the proposed measures would bring to taxpayers, aside from potentially addressing some very specific or limited circumstances.’ How have plans to reform Ireland’s taxation regime for interest evolved in 2026 and what are the key changes that would result in ‘tangible benefits’ for Irish corporate taxpayers?
1907 Limited Partnership: The Department of Enterprise, Tourism and Employment have committed to updating the 1907 Limited Partnership and have recently conducted a public consultation on reform of the framework. Are there tax aspects that could also be considered as part of the reforms to enhance the 1907 LP?
Ireland for Finance: The Department of Finance launched the latest Ireland for Finance strategy on 25th August. The strategy outlines the planned (and in some cases, ongoing) tax reforms in the areas of R&D, taxation on interest (see Question 3) and Section 110. In your view, what other aspects of Ireland’s tax regime, if reformed, could support the goals outlined in the IFF strategy - ‘to incentivise entrepreneurship, fostering innovation, and enhancing the competitiveness of our tax framework for inward investment’?
Tax Management: What are key challenges facing the corporate tax manager in the coming 12-18 months? What steps can be taken to prepare to meet these challenges?