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Ireland Archive

  • December 2014

    European Commission to seek information on tax rulings from all member states

    December 17, 2014

    The European Commission has expanded its state aid inquiry into tax rulings to cover all 28 EU member states.

  • Digital goods enter the 21st century of taxation

    December 16, 2014

    Richard Asquith, VP of Global Tax Compliance at Avalara, explains upcoming changes to European Union VAT rules and how they will affect digital service providers from January 1 2015. The changes are contained within article 58 2006/122/EC of the EU VAT Directive and all 28 member states are in the process of ratifying the changes through local VAT legislation.

  • Ireland: Changes to Irish corporate residence rules

    December 16, 2014

  • Italy: Italy announces Patent Box regime from 2015

    December 16, 2014

  • Anti-abuse clause added to EU Parent-Subsidiary Directive

    December 16, 2014

    The Council of the European Union has approved an amendment to the EU Parent-Subsidiary Directive in a clampdown on aggressive corporate tax avoidance.

  • Irish air travel tax under renewed scrutiny as ECJ partially annuls 2011 EC decision

    December 02, 2014

    The ECJ has partially annulled a 2011 decision that elements of the Irish air travel tax (ATT) did not constitute state aid.

  • The attractiveness of Ireland’s ICAV regime

    December 01, 2014

    On July 29 2014, the Irish Government published the Irish Collective Asset Management Vehicle Bill 2014 (the ICAV Bill). The ICAV Bill, when enacted, will provide for a corporate vehicle structure specifically designed to meet the needs of the global funds industry with several advantages over the existing corporate structure (that is, the public limited company (plc)) for collective investment schemes in Ireland. The Irish Government has indicated that the ICAV Bill will be enacted before the end of 2014.

  • November 2014

    EC’s Raponi speaks about future of EU VAT mini one-stop shop

    November 21, 2014

    Donato Raponi, head of the European Commission’s VAT Unit, has spoken about the potential for the scope of the EU’s VAT mini one-stop shop (MOSS), which will be rolled out from January 1 2015, to be expanded further.

  • Irish Revenue publishes revised Code of Practice for Revenue Audit and other Compliance Interventions

    November 19, 2014

    The Irish Revenue authority (Revenue) has published a revised Code of Practice for Revenue Audit and Other Compliance Interventions (the Revised Code), which took effect from August 14 2014. It will be a “live” document, meaning it will remain under permanent review and be updated to reflect changes in legislation and new practices.

  • European IP tax regimes set for reform after UK-Germany agreement

    November 11, 2014

    The scope of the UK Patent Box regime is to be restricted after Germany and the UK reached agreement to reduce the competitive advantages it provides. The restrictions are likely to be extended to other European intellectual property (IP) tax regimes.

  • Significance of Skandia VAT case hinges on interpretation - and translation - of key paragraph

    November 07, 2014

    The significance of the Skandia ruling for taxpayers across Europe depends on domestic VAT grouping rules, and interpretation of the ruling should be taken from the original Swedish verdict.

  • Luxembourg comfort letter tax deals could spell trouble for EC’s Juncker

    November 06, 2014

    The leaking of documents detailing tax arrangements Luxembourg has agreed with hundreds of corporate taxpayers is adding to pressure on Jean-Claude Juncker, president of the European Commission, after last month’s state aid investigation launches into deals signed by the Grand Duchy while Juncker was prime minister had already cast doubt on the appropriateness of his Commission appointment.

  • October 2014

    Singapore: Global intellectual property hub in Asia

    October 30, 2014

    Over the years, Singapore has been taking active steps to position itself as an intellectual property (IP) hub in Asia. Harvey Koenig, tax partner at KPMG in Singapore, explores how, in this innovation-driven globalised economy, IP has become an important driver of growth.

  • Ireland: Ireland ready for VAT Mini-One-Stop-Shop

    October 30, 2014

  • Netherlands tops table of best VAT collectors as EU VAT gap grows to €177 billion

    October 29, 2014

    The Netherlands has again ranked at the top of the European Commission’s annual study into the VAT gap – the difference between expected VAT revenue and actual revenue collected – meaning its compliance and enforcement measures are the most efficient in the region, but the EU VAT gap grew to €177 billion.

  • Kokott takes aim at Marks and Spencer exception on EU group loss relief again

    October 24, 2014

    Juliane Kokott, an Advocate General of the European Court of Justice (ECJ), believes the Court’s decision on group loss relief in the Marks & Spencer case should be overturned.

  • Moscovici signals intention to bring in financial transaction tax

    October 23, 2014

    Members of the European Parliament (MEPs) have voted 423 to 209 to approve Jean-Claude Juncker’s new EU Commission team, including new taxation commissioner, Pierre Moscovici. The appointment could have a big impact on European tax harmonisation.

  • EU launches new web portal to ease transition to new VAT rules

    October 15, 2014

    The European Commission has developed a new web portal and a ‘mini one stop shop’ to help businesses prepare for the changes in VAT collection rules.

  • Irish Budget 2015 – Key international tax aspects

    October 14, 2014

    Ireland adopts first mover advantage including commitment to a best-in-class knowledge development box – a clear roadmap for the future

  • Time is up for the double Irish

    October 14, 2014

    The Irish government announced in its 2015 Budget today the abolition of the so-called double-Irish structure and its intention to introduce an income-based system for the taxation of intellectual property, which it is calling a Knowledge Development Box.

  • Ireland’s tax deals with Apple “constitute state aid”; Luxembourg’s Amazon arrangement also called into question

    October 06, 2014

    Amazon has been drawn into a European Commission (EC) investigation into the tax regimes of three member states: Ireland, Luxembourg and the Netherlands. The EC has said its preliminary view on Ireland is that “the tax rulings of 1990 (effectively agreed in 1991) and of 2007 in favour of the Apple group constitute state aid”.

  • Ireland produces guidance notes for FATCA implementation

    October 03, 2014

    The Revenue Commissioners in Dublin have published guidance notes on America’s Foreign Account Tax Compliance Act (FATCA), giving financial institutions in Ireland more information about how they should comply with the due diligence and reporting requirements in the controversial law.

  • OECD unveils plan for 2014/2015 BEPS work

    October 02, 2014

    The OECD is getting straight back to work on base erosion and profit shifting (BEPS).

  • Non-regulatory scrutiny: The tax lifecycle’s latest frontier

    October 01, 2014

    Chris Walsh and Bernadette Pinamont of Vertex look at the rise of public, non-regulatory scrutiny of multinational tax affairs, and outline best practices for in-house tax teams to deal with such scrutiny.

  • September 2014

    G20 tax agenda is not all about BEPS

    September 26, 2014

    The G20’s finance ministers have outlined their plans to minimise global tax avoidance and evasion, which are not only about completing the work of the BEPS Action Plan on time by the end of next year.

  • Holding Companies Focus 2014 now available

    September 16, 2014

    Leading advisers from Eurofast in Cyprus, Grant Thornton in Ireland, KPMG in Malta and KPMG in Switzerland explain what each of their jurisdictions is doing to strengthen their appeal as holding company locations.

  • The tax market reacts to the BEPS 2014 deliverables: Do you agree?

    September 16, 2014

    The OECD today unveiled its 2014 deliverables at the halfway stage of the multilateral organisation’s ambitious base erosion and profit shifting project, commissioned by the G20, which represents the biggest ever review of international tax rules.

  • World's leading tax controversy advisers unveiled

    September 05, 2014

    The fourth edition of International Tax Review's Tax Controversy Leaders guide is out now. Find out who the top-rated disputes specialists are in your jurisdiction.

  • August 2014

    World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • Inversions highlight antiquated US tax system

    August 22, 2014

    Comment: Far from representing the lack of economic patriotism of US companies, the trend of inversions out of the US is indicative of just how antiquated the US tax code is.

  • Inversions - special focus

    August 10, 2014

    Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.

  • July 2014

    Pfizer and AstraZeneca go separate ways…for now

    July 31, 2014

    After the failure of the Pfizer-AstraZeneca transaction at the end of May, the two companies have now announced new deals with other companies. But the two drugs companies could return to the proposed inversion deal later this year.

  • Irish-German relationships – tension over tax?

    July 25, 2014

    A recent report criticising Ireland’s economic growth plan – initially labelled as coming from the German Bundestag Finance Committee – has caused controversy and tension in Irish-German relations, but an analysis of the facts shows the report does not wholly represent German attitudes towards Ireland.

  • US lawmakers call for greater economic patriotism as inversions continue

    July 25, 2014

    The Senate Finance Committee this week held a hearing on proposals to reform the taxation of multinational enterprises, and given the recent trend of US companies inverting abroad, the hearing unsurprisingly focused on dealing with inversions.

  • OECD answers your questions about the global automatic exchange standard

    July 24, 2014

    EXCLUSIVE: On Monday July 21 the OECD released the full version of the Standard for Automatic Exchange of Financial Account Information in Tax Matters, which requires financial institutions to report detailed financial account information to their governments, which then exchange such information automatically with other jurisdictions on an annual basis. The Standard developed by OECD in response to a mandate by the G20 was first presented to and endorsed by the G20 Finance Ministers in February 2014.

  • Automatic exchange of information gets closer with OECD's publication of global standard

    July 21, 2014

    The OECD today unveiled the full version of the new global standard for automatic exchange of information between jurisdictions, which will be presented to the meeting of G20 finance ministers in Cairns, Australia on September 20 and 21.

  • Inversions trend continues to cause controversy

    July 18, 2014

    Medtronic and Covidien announced last weekend that they intend to complete a $43 billion tie-up and fellow US pharmaceutical company, AbbVie, is set to send a formal $31 billion offer for Irish rival Shire today: the trend of inversion transactions out of the US shows no signs of abating.

  • Why Danaher Corporation is not looking to invert

    July 18, 2014

    Despite the recent spate of corporate inversion transactions, not all US taxpayers have caught the inversion bug. Danaher Corporation's Jim Ditkoff tells International Tax Review "Congress can do whatever they want with inversions as far as I'm concerned". Here he explains why Danaher is not following the herd by inverting overseas.

  • Have your say on ITR's development

    July 14, 2014

    The new website went live in late May. Take the opportunity to influence how it develops by completing our survey.

  • Semeta extols EU efforts on tax compliance and promises more

    July 10, 2014

    Algirdas Semeta has said European taxpayers should see big improvements in compliance in the coming years.

  • Companies under pressure to consider inverting

    July 04, 2014

    The popularity of corporate inversion transactions has grown considerably in the past few years, with notable examples including Medtronic-Covidien, Actavis-Warner Chilcott, Elan-Perrigo and Liberty Global-Virgin Media. Now shareholders in US companies are asking: “If our rivals are doing this, is it something we should be considering?”

  • Is tax competition bad?

    July 02, 2014

    With accusations of cosying up to multinationals and engaging in a race to the bottom, there is an assumption that tax competition is bad. But panellists at the Oxford Business School’s Summer Conference on Tax Competition and BEPS questioned whether the perception matches reality.

  • BEPS and the digital economy: Why is it so taxing to tax?

    July 01, 2014

    Devising appropriate rules for the taxation of the digital economy is one of the most awkward challenges governments have set for themselves in the BEPS project, especially when defining the digital economy is an issue in itself. Aaran Fronda looks at the possible outcomes of the discussion.

  • In search of harmony: Finding a consensus on hybrid mismatches

    July 01, 2014

    Mismatches create opportunities. This is true in any scenario, whether it is the opportunity for a fleet-footed and nimble winger to gain an advantage by exposing the bulky, flat-footed front-row rugby forward who has temporarily become his opposite man, or whether it is in the (equally ruck-filled) field of tax planning. Matthew Gilleard looks at where the OECD is drawing the line when it comes to activity that takes advantage of tax law mismatches in an intended or acceptable manner, and that which is not.

  • European Tax Awards 2014

    July 01, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • June 2014

    G8 has “broken promises” on tax transparency

    June 25, 2014

    Christian Aid, ActionAid, Global Witness and the Financial Transparency Coalition have accused G8 countries of failing to live up to the promises they made on tax and transparency a year ago at the Lough Erne summit in Northern Ireland.

  • Indirect Tax Leaders 2014 now available

    June 23, 2014

    The third edition of International Tax Review's Indirect Tax Leaders' Guide, is all about identifying the leading professionals in this field, which is only increasing in importance. Between its covers, you will find the names, and biographies in many cases, of the world's leading indirect tax practitioners, which were collected after an independent research process. It should give taxpayers confidence that if they decide to hire any of these individuals, they will be getting the best in the field.

  • Irish tax law and practice: Interaction with state aid rules

    June 19, 2014

    The launch of an in-depth investigation by Joaquín Almunia, EU Competition Commissioner, into tax authority decisions relating to transfer pricing arrangements in Ireland, the Netherlands and Luxembourg brings a new dynamic to the debate on harmful tax competition. The timing of the investigation is unfortunate, given the reporting timeframe for the OECD’s BEPS and Ireland's active participation in that debate.

  • Apple, Fiat and Starbucks rulings attract state aid investigations

    June 13, 2014

    The European Commission has opened formal state aid investigations into three tax rulings agreed between Apple, Fiat and Starbucks with the Irish, Luxembourg and Netherlands tax authorities, respectively.

  • Wallace joins William Fry

    June 12, 2014

  • Ireland: High Court decides providers of pension schemes are not required to verify bona fides of transfer

    June 02, 2014

    In Michael O’ Sullivan v Canada Life Insurance [Ireland] Limited, the Irish High Court ruled on two aspects relating to the transfer of Personal Retirement Savings Account (PRSA) abroad pursuant to the Occupational Pension Schemes and Personal Retirement Savings Accounts (Overseas Transfer Payments) Regulations 2003 (the Regulations).

  • Ireland: Revenue Annual Report 2013

    June 02, 2014

    Revenue recently published their annual report for 2013. The report sets out some of the major trends in terms of Revenue’s audit and enforcement activity in Ireland, during 2013. Outlined below is a summary of some of the key points raised in the report.

  • Why do publicly-traded companies like Ireland?

    June 01, 2014

    Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the factors influencing taxpayer decisions to locate in Ireland, debunking the idea that such decisions are solely tax-driven.

  • Pharma and Irish inversions: Increasing your share price

    June 01, 2014

    A spate of recent examples indicates that inversion transactions are as popular as they have ever been, with Pfizer’s attempted deal with AstraZeneca highlighting that companies in the pharmaceuticals industry are increasingly using the inversion option. William Fry Tax Advisors, the Irish member firm of Taxand, look at why this is, and analyse why Ireland is proving to be the location of choice for newly-formed companies post-inversion.

  • May 2014

    Inversions: The trend turning transactional tax planning upside down

    May 27, 2014

    Mention the word ‘inversion’ or ‘inverted’ and the first things likely to come to mind for most people are inverted commas – the most supercilious of the English language’s punctuation marks, looking down on regular commas from their lofty perch with scorn. Possibly La Pyramide Inversée at Le Louvre, too. But mention those words today and a tax efficient restructuring mechanism may also feature. Matthew Gilleard explores the inverted reality of this transactional trend.

  • Why do publicly-traded companies like Ireland?

    May 27, 2014

    Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the factors influencing taxpayer decisions to locate in Ireland, debunking the idea that such decisions are solely tax-driven.

  • Pharma and Irish inversions: Increasing your share price

    May 27, 2014

    A spate of recent examples indicates that inversion transactions are as popular as they have ever been, with Pfizer’s attempted deal with AstraZeneca highlighting that companies in the pharmaceuticals industry are increasingly using the inversion option. William Fry Tax Advisors, the Irish member firm of Taxand, look at why this is, and analyse why Ireland is proving to be the location of choice for newly-formed companies post-inversion.

  • Avoiding the snares of international tax structures

    May 27, 2014

    International business expansions can substantially increase the bottom line, but this outcome is largely dependent on establishing an efficient structure that helps to ensure financial success. Lee Sheehan, head of tax at Radius, looks at the importance of a clear strategy when setting up tax structures for specific business locations, and points out some of the landmines to avoid along the way.

  • European Tax Awards' winners unveiled

    May 22, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • Switzerland moves to strengthen corporate competitiveness

    May 22, 2014

    Switzerland will implement changes to its corporate tax regime at federal and cantonal level in an effort to preserve the country’s tax appeal.

  • World Tax 2016 and World Transfer Pricing 2016: Research opens in May 2015

    May 21, 2014

    The research will start for the 2016 editions of World Tax and World Transfer Pricing in May 2015. Please watch this website closely for further information.

  • Declaration commits OECD and other countries to automatic exchange of information

    May 07, 2014

    Taxpayers must get used to the Common Reporting Standard as the means for the introduction of automatic exchange of tax information around the world.

  • US updates FATCA list of intergovernmental agreements

    May 02, 2014

    The number of jurisdictions considered to have an intergovernmental agreement (IGA) in place with the US for the implementation of the Foreign Account Tax Compliance Act (FATCA) has passed 50.

  • April 2014

    According to plan? The world of tax planning is changing, but not as fast as everyone would like

    April 30, 2014

    The world of tax planning is like one big global tug o’ war being played between multinational companies and their advisers, tax authorities, supranational bodies and non-governmental organisations. Everyone has an interest in changing the international tax system. But with everyone pulling in different directions, the pace of change is frustrating for most.

  • The journey into the future for Swiss principal companies?

    April 30, 2014

    Urs Landolf, Martina Walt and Christoph Pauli of PwC explain the impact new interpretations of principal company taxation by the Swiss federal tax authorities will have on all existing companies benefiting from circular no 8.

  • Investment funds could be in the money after European court ruling against Poland

    April 11, 2014

    A European Court of Justice decision in favour of a US investment fund could cost EU member states billions of euros in withholding tax reclaims.

  • Nominations announced for European Tax Awards 2014

    April 10, 2014

    Deloitte and EY lead the race for International Tax Review’s 10th annual European Tax Awards, which will be presented at a dinner in London on May 21.

  • Clarity behind US move to add 22 jurisdictions to FATCA list

    April 04, 2014

    It is not a global information reporting network yet, but the US Treasury and Internal Revenue Service’s announcement this week that increases the number of intergovernmental agreements for the Foreign Account Tax Compliance Act (FATCA) from 26 to 48 in one go brings that idea much closer.

  • March 2014

    Operational TP: When tax function meets finance function

    March 28, 2014

    Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.

  • Adopting an Irish parent

    March 28, 2014

    From management consultants Accenture, to major pharmaceuticals including Perrigo, Forest Labs and Warner Chilcott, to manufacturer and equipment supplier Eaton Corporation to one of the world’s leading insurance groups, Willis, the shift to adopting an onshore Irish incorporated tax resident parent is gathering pace. Mason Hayes & Curran considers the rationale for such a shift and the long-term value creation for shareholders yielded by the shift.

  • US signs FATCA intergovernmental agreements with Chile and Finland

    March 12, 2014

    Chile and Finland have become the 23rd and 24th jurisdictions to sign bilateral intergovernmental agreements (IGA) to implement the Foreign Account Tax Compliance Act (FATCA) as the US moves slowly towards signing more than 50 with jurisdictions around the world.

  • February 2014

    Big fish: The world's leading transactional firms revealed

    February 26, 2014

    International Tax Review analyses the global M&A trends over the last year and highlights the leading firms in the field.

  • UK government rejects proposal to reduce tourism VAT

    February 18, 2014

    David Gauke, Exchequer Secretary to the Treasury, has rejected a 15 percentage point cut in VAT for the tourist sector, despite evidence it will boost GDP, create jobs and increase fiscal revenue.

  • OECD standard makes progress towards automatic exchange of information

    February 13, 2014

    Global automatic exchange of financial account information got a step closer today after the OECD published its Common Reporting Standard.

  • OECD seeks increased tax transparency from multinationals

    February 06, 2014

    The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

  • January 2014

    The dark side of transparency

    January 28, 2014

    Tax transparency is lauded as an unequivocal good. But is it really this clear-cut? Matthew Gilleard explores the negatives as he ventures into the dark side of transparency.

  • Special features - February 2014

    January 28, 2014

    Read this month's special features on Canada and Tax compliance.

  • Getting value from advisers: An in-house perspective

    January 28, 2014

    Patrick Connolly is an experienced senior in-house tax adviser who has spent the past 10 years in in-house regional tax roles covering Europe, the Middle East, Africa and the Asia/Pacific regions as well as head office tax responsibilities. He shares his views on getting the most value from the client/adviser relationship. Paul Dunne, national managing tax partner for KPMG New Zealand and the tax lead on a number of multinational clients, provides his response and comments.

  • Tax, development and the new Millennium Development Goals

    January 28, 2014

    Seth Terkper, Ghana’s minister of finance, and Hafiz Choudhury, senior adviser, International Tax and Investment Centre, discuss the challenges for developing countries in creating tax systems that raise enough revenue to fund development and also encourage investment.

  • The Irish ICAV corporate investment vehicle and its impact on taxation

    January 22, 2014

    Lisa Dunne of William Fry discusses the ICAV: A new corporate investment vehicle specifically designed for Irish funds, which has been announced by the Minister for Finance.

  • European Tax Awards 2014: submissions period now open

    January 20, 2014

    Companies and firms can now enter for the European Tax Awards 2014. Entry information is available in hyperlinks throughout this story.

  • Reform of the tax appeal process in Ireland

    January 14, 2014

    Taxpayers and practitioners have until the end of January to respond to a consultation on the reform of how tax appeals take place in Ireland.

  • Italy imposes Google tax on web advertising

    January 08, 2014

    Italy’s parliament has passed the Google tax which will require companies to buy internet advertisements from locally-registered companies and not from companies based in tax havens including Bermuda and Ireland. But the proposal may violate EU laws on non-discrimination regarding commercial activity.

International Correspondents