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Ireland Archive

  • December 2015

    The Cunningham column: China gets ready to lead tax world in 2016

    December 15, 2015

    China will be at the forefront of BEPS implementation in 2016, as president of the G20. Ralph Cunningham says it is a big opportunity for a non-OECD member to shape the international tax system.

  • The Brockman brief: BEPS implementation: A holiday wish

    December 15, 2015

    Drafters of the new base erosion and profit shifting (BEPS) actions and precision watchmakers share a common wish; that their immeasurable efforts devoted to refining and juxtaposing complex parts result in an instrument that is respected and trusted around the world.

  • BEPS Special

    December 15, 2015

    Matthew Gilleard introduces this exclusive, comprehensive insight into the work of the OECD in the area of countering tax base erosion and profit shifting (BEPS). Within these covers you will find out about the key messages delivered under each of the OECD’s 15 Actions, direct from the individuals responsible for putting each aspect of the project together.

  • Intercompany charges below EBIT: A double-edged sword

    December 15, 2015

    Luis Abrantes, tax director and head of transfer pricing at Carlsberg Group, draws on practical experiences to unpick the intricacies of intercompany charges.

  • Ireland: Ireland confirms AT1 instruments treated as debt

    December 15, 2015

  • Intangible contributions in the automotive industry under BEPS

    December 15, 2015

    In the fourth of a series on intangibles, Philip de Homont and Alexander Voegele, both of NERA Frankfurt, examine how to deal with contributions by many group companies.

  • 2016 Look-Ahead: BEPS implementation to dominate international tax landscape

    December 15, 2015

    With the final deadlines for the OECD’s BEPS Project falling at the end of this year, 2016 was always going to be a year dominated by questions about implementation. While BEPS-related activity is not the only issue on the horizon, that alone will ensure multinationals are kept busy over the next 12 months. Joe Stanley-Smith and Matthew Gilleard look through the peephole to analyse taxpayer hopes, fears and expectations for the year ahead.

  • Pfizer-Allergan: How the US tax code is pushing companies through the exit door

    December 11, 2015

    Pfizer’s $160 billion acquisition of Allergan shows that highly-mobile American companies are still looking to “self-help” action such as inversion as the US tax code fails them on competitiveness.

  • November 2015

    EC grills 11 LuxLeaks multinationals on tax; extends mandate for tax rulings investigation

    November 26, 2015

    Following the questioning of Anheuser-Busch InBev, Coca-Cola, Disney, IKEA, Amazon, Google, HSBC, Barclays, Facebook, Philip Morris International and McDonald’s, the mandate of the European Commission’s (EC’s) TAXE Committee has been extended.

  • Northern Ireland’s push for fiscal control

    November 26, 2015

    A deal to resolve the political debate over Northern Ireland’s corporate tax autonomy has been announced, which will lead to a 12.5% Northern Irish corporate tax rate from April 2018.

  • The UK’s tax policy battleground: Gauke vs Marris on top tax myths

    November 25, 2015

    Financial Secretary to the UK Treasury David Gauke and the opposition Labour MP shadowing him, Rob Marris, have shared a platform for the first time since May’s election.

  • October 2015

    Mind your own business: The importance of knowing what we really do

    October 29, 2015

    Steven Ouwerkerk, global head of tax at APM Terminals, argues that to deal with the corporate challenges of operating in an increasingly borderless world, multinationals must learn to operate in a department-less manner, sharing experiences across functions and understanding issues from a variety of perspectives. He also brings a new meaning to the phrase ‘mind your own business’.

  • Brand management centres in the age of BEPS

    October 29, 2015

    In the third of a series on intangibles, Philip de Homont and Alexander Voegele, both of NERA Frankfurt, look at brand management centres in the age of BEPS.

  • The Brockman brief: Tax transparency: Is it a one-way street?

    October 29, 2015

    The envisaged ideals of ‘tax transparency’ are being proposed, and legislated, by tax administrations worldwide. This month’s Brockman brief focuses on the fact that mutual and reciprocal tax transparency with multinational entities (MNEs) remains somewhat elusive. It is now time to briefly assess some of these initiatives to fairly gauge the mutuality of such initiatives.

  • Irish Finance Bill: Country-by-country reporting

    October 29, 2015

    The Irish Finance Bill published on October 22 2015 contains details of Ireland's response to Action 13 of BEPS - the minimum standard of country-by-country reporting (CbCR).

  • BEPS implementation: The role of a multilateral instrument

    October 27, 2015

    Jeffrey Owens, director of the Global Tax Policy Centre at the Vienna University of Economics and Business (WU) Institute for Austrian and International Tax Law (IAITL) and former OECD tax chief, and Nathalie Bravo, research associate at the IAITL, explore the role of a multilateral tax instrument in implementing BEPS Project measures, and analyse the treaty issues and technical challenges to be overcome.

  • Ireland's 6.25% Knowledge Development Box

    October 23, 2015

    The Irish Finance Bill was published on October 22 2015. Besides country-by-country reporting, it provides draft legislation of the first OECD modified nexus intellectual property box – the Knowledge Development Box (KDB). As expected, the tax rate applying to eligible income under the new regime will be 6.25%. Gains from the disposal of IP remain taxable at 33%.

  • Facebook to face UK PAC scrutiny over low tax bill

    October 15, 2015

    Facebook was on the front page of one of the UK’s most-read daily newspapers for all the wrong reasons this week after it emerged the company paid £4,327 ($6,702) in corporate tax in 2014.

  • Irish Budget 2016: 6.25% IP box and CbCR

    October 13, 2015

    Michael Noonan, Irish finance minister, today delivered his Budget 2016 speech. Taxpayers around the world were keen to see how the country amended its international tax provisions in the wake of OECD recommendations in this area.

  • Lenaerts to serve three-year term as ECJ President

    October 12, 2015

    Koen Lenaerts has been elected by his peers to a three-year presidential term at the helm of the European Court of Justice (ECJ). Antonio Tizzano will serve as vice-president.

  • Ireland

    October 02, 2015

  • September 2015

    The Brockman brief: Performance review: The OECD’s reputation

    September 29, 2015

    The curtain is drawing to a close on the final OECD BEPS recommendations, while the OECD actors and supporting staff anxiously await reaction from the audience. This month’s Brockman brief runs the rule over the OECD’s BEPS work to date and looks ahead to see how developments are likely to impact the organisation’s reputation as the ‘go-to’ body for international tax matters.

  • DSM to be enhanced during destination principle expansion

    September 29, 2015

    Key figures at the European Commission have outlined the importance of the digital single market (DSM) as they prepare to extend the destination principle and mini one-stop shop (MOSS). Joe Stanley-Smith investigates.

  • Moscovici calls for action as EU VAT gap rises again

    September 29, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has urged EU member states to tighten up VAT collection after new figures showed €168 billion was lost in 2013. Joe Stanley-Smith reports.

  • Ireland: Irish Revenue Commissioners issue guidance on the VAT treatment of portfolio management services in wake of Deutsche Bank

    September 29, 2015

  • License fees determined by the ‘willingness-to-pay’

    September 29, 2015

    In the second of a series of updates on intangibles valuation and intellectual property (IP) assets, NERA principal Philip de Homont and affiliated consultant Alexander Voegele look at intangibles that allow companies to charge higher prices, and methods used to determine license fees.

  • Moscovici calls for action as EU VAT gap rises again

    September 16, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has urged EU member states to tighten up VAT collection after new figures showed €168 billion was lost in 2013.

  • Broad VAT debate at Fiscalis conference

    September 09, 2015

    A three-day VAT conference attended by business representatives, industry bodies and all 28 EU member states’ tax authorities concluded on Wednesday 9 September. The discussions have laid the groundwork for future legislative proposals.

  • EU tax officials descend on Dublin for key VAT conference

    September 07, 2015

    Taxpayers’ eyes will be on Dublin, Ireland today when a key conference on the future of VAT in the EU kicks off. Key discussions around the destination principle and the mini one-stop shop (MOSS) will take place.

  • Ireland

    September 03, 2015

  • August 2015

    Issues the economist forgets? TP policy – a banking perspective

    August 21, 2015

    After spending 15 years in-house, Ben Henton last month joined BDO as a transfer pricing director. He returns to the UK from Asia after four years working at HSBC and DBS Bank in Hong Kong and Singapore. Here, he addresses operational risk challenges in transfer pricing (TP) from an in-house perspective, going beyond technical TP legislation and guidelines.

  • Ireland: Recent developments in Ireland’s R&D tax credit regime

    August 21, 2015

  • What effect could the Altera decision have on non-US companies and subsidiaries?

    August 14, 2015

    A recent decision in Altera Corporation vs Commissioner has seen a portion of treasury regulations relating to cost-sharing agreements (CSAs) on stock-based compensation ruled as invalid.

  • July 2015

    Kokott recommends Europe exempts Bitcoin from VAT in ECJ Opinion

    July 21, 2015

    Cryptocurrencies such as Bitcoin should be exempt from VAT, according to Advocate General Juliane Kokott’s Opinion in a Swedish European Court of Justice (ECJ) case.

  • Proposed Greek 26% transaction tax faces EC investigation

    July 13, 2015

    A proposed Greek 26% transaction tax, which has caused concern and uncertainty for businesses in Bulgaria, Cyprus and Ireland, is being scrutinised by the European Commission (EC), which will convene a meeting with the parties concerned and provide its opinion on August 18.

  • The Brockman brief: Illusory transparency: A symptom of BEPS complexity

    July 10, 2015

    The inception of the OECD’s base erosion and profit shifting (BEPS) action plans was accompanied by new demands for fiscal transparency, ignoring omnipresent thorns of complexity.

  • Vicious and virtuous circles: Planning for change with Schroders’ group tax head

    July 10, 2015

    Joe Stanley-Smith talks to Sue Cooper, group head of tax at global asset management company Schroders, about inter-departmental cooperation, planning for change and the difference between vicious and virtuous circles.

  • European Tax Awards 2015

    July 10, 2015

    The Grosvenor House Hotel on London’s Park Lane was the new venue for the 11th annual European Tax Awards dinner on May 21.

  • Dineen is new tax partner at Mason Hayes & Curran

    July 08, 2015

    Maura Dineen has become a partner of Mason Hayes & Curran in Dublin.

  • June 2015

    Financial Services Supplement 2015 now available

    June 29, 2015

    Leading advisers provide insights on the latest financial services tax issues from jurisdictions around the world.

  • Saint-Amans and Bhatia hit out at EU non-cooperative list

    June 24, 2015

    The OECD, and the Global Forum on Tax Transparency and Exchange of Information, which it organises, have moved to assert their preeminence as the international bodies that discuss and decide on transparency and exchange of information standards.

  • Ireland

    June 23, 2015

  • EU's tax transparency consultation keeps focus on public disclosure

    June 18, 2015

    The European Commission said the aim of the public consultation into tax transparency, which it launched on June 17, is to learn whether the public wants corporations to disclose more about the taxes they pay and if this "could help to tackle tax avoidance and aggressive tax practices in the EU".

  • Common tax base at fore of European Commission's plans for corporate taxation

    June 17, 2015

    The European Commission launched its much-anticipated Action Plan on Corporate Taxation today, basing it on the idea of the Common Consolidated Corporate Tax Base as a 'holistic solution to corporate tax reform' and the principles of ensuring effective taxation and increasing transparency.

  • Deloitte Ireland adds two new tax partners

    June 17, 2015

    Karen Frawley and Daryl Hanberry have been made partners in Deloitte Ireland’s tax department, as part of the firm’s latest round of promotions to the partnership, which saw six others move up in other departments.

  • HMRC’s light touch approach for EU VAT extended indefinitely

    June 17, 2015

    The UK revenue authority, HMRC, has confirmed that it will extend its ‘light touch’ approach for the 2015 EU VAT regulations “indefinitely”. The policy had been due to expire at the end of June 2015.

  • Ireland updates mandatory disclosure regime

    June 01, 2015

    Brian Duffy of William Fry Tax Advisors – Taxand Ireland looks at the impact changes to Ireland’s GAAR will have on the country’s mandatory disclosure regime.

  • May 2015

    The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • ETFs - preparing for future tax challenges

    May 27, 2015

    Exchange traded funds (ETFs) have been a huge success growing far beyond their initial function of tracking large liquid indices in developed markets. Global ETFs now hold more than $2.9 trillion of assets in upwards of 5,400 products listed on 60 exchanges. Marie Coady, financial services tax partner at PwC in Ireland, tackles the associated tax and regulatory challenges.

  • Ireland: Tax treatment of exchange traded funds

    May 27, 2015

  • European Tax Awards 2015 - the winners

    May 22, 2015

    The European Tax Awards 2015 were presented on May 21 at a dinner at the Grosvenor House Hotel in London.

  • Ansip to propose EU-wide VAT threshold “as soon as possible”

    May 19, 2015

    Andrus Ansip, European Commission vice president for the digital single market, has promised to launch a proposal for an EU-wide VAT threshold on business-to-consumer (B2C) e-services “as soon as possible”.

  • EC's digital single market strategy aims to reform VAT for B2C online retailers by 2017

    May 13, 2015

    The European Commission‘s ambitious plans to improve the digital single market include changes to the VAT treatment of the cross-border supply of goods and services.

  • Vestager delays verdict on EC state aid investigations in to Apple, Amazon, Starbucks and Fiat

    May 13, 2015

    The European Commission (EC) will miss its June deadline to complete state aid investigations into tax rulings for Amazon, Apple, Fiat and Starbucks, competition commissioner Margrethe Vestager has announced.

  • April 2015

    The Brockman brief: Timing symmetry is shattered: CbCR and TP documentation

    April 28, 2015

    May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

  • Tax planners' task tougher than ever

    April 28, 2015

    Failing to plan is planning to fail. We are all familiar with the phrase. But practising what one preaches in this regard has never been more important for corporate taxpayers.

  • VAT MOSS: EU to review B2C digital services rules

    April 15, 2015

    The European Commission (EC) will review its 2015 changes to VAT paid on business-to-consumer (B2C) supplies of digital services, which were implemented on January 1 2015. MOSS critics say delaying the review process could leave the digital single market “dead in the water”.

  • Australian inquiry scrutinises Apple, Google, Microsoft tax structures

    April 08, 2015

    Apple, Google and Microsoft have denied that they avoid tax during a day-long grilling by Australian senators.

  • World Tax and World Transfer Pricing 2016: The research period is now open

    April 02, 2015

    Don't miss out on your chance to be included in International Tax Review's directories of the leading tax and transfer pricing firms around the world.

  • March 2015

    European Tax Awards 2015 - the shortlists are out

    March 30, 2015

    The nominees have been revealed for International Tax Review's European Tax Awards 2015.

  • The Brockman brief : TP risk determination: Transparency and mutuality

    March 25, 2015

    This month, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, runs the rule over issues of transfer pricing risk determination, focusing on transparency and the benefits of increased levels of authority reciprocity.

  • Irish Revenue official: Bringing MOSS to life

    March 25, 2015

    The new EU legislation changing the place of supply of business-to-consumer (B2C) electronic services, telecommunications and broadcasting to the country of the consumer has been the VAT story of the year. Joe Stanley-Smith speaks to Dermot Donegan, head of VAT policy at the Irish tax authority (Revenue), about how the plans were finalised during the Irish presidency of the EU Council, his thoughts around their implementation and the possibility of expanding the mini one-stop shop (MOSS) to cover goods and other services.

  • Ireland outlines international financial services strategy

    March 25, 2015

    The recent release of Ireland’s major strategy paper, ‘IFS2020 – A strategy for Ireland’s financial services sector 2015-2020’ addresses Ireland’s five year strategy in further developing the country as a global leader in the financial services sector.

  • Irish tax regime for securitisation vehicles

    March 23, 2015

    Securitisation has been commonly used for a variety of financial transactions ranging from the securitising of loan books to real asset holding such as aircraft. Lord Hill, EU commissioner, has announced an intention to reconsider the EU’s approach to securitisation and identify elements where the regulatory burden for investors can be lightened, but Ireland already has provisions which make it a popular location for securitisation vehicles.

  • Irish tax regime for shipping operations

    March 20, 2015

    It is widely recognised that Ireland is one of the major worldwide hubs for aircraft leasing and related financing structures. What is less well known is that Ireland’s tax system has been tailored to suit the needs of companies that require a base for shipping operations.

  • European Commission unveils tax transparency measures and makes automatic exchange of information central to combating evasion

    March 19, 2015

    The European Commission is promoting its Tax Transparency Package, published yesterday (March 18), as a tool for “healthier” tax competition as well as for helping member states identify abusive tax practices.

  • Changes to Ireland's general anti-avoidance regime

    March 09, 2015

    The Finance Act 2014 introduced substantial changes to Ireland's general anti-avoidance rule (New GAAR).

  • Goods vs services: ECJ rules against France and Luxembourg in e-books dispute

    March 06, 2015

    The European Court of Justice (ECJ) has ruled that France and Luxembourg cannot apply a reduced VAT rate to e-books, despite a reduced rate being acceptable for physical books.

  • Lamassoure to run European Parliament committee on tax rulings

    March 04, 2015

    A French member of the European Parliament will front that institution's probe into tax rulings in EU member states.

  • MOSS registration figures lower than expected

    March 04, 2015

    Around 7,000 businesses have registered for the EU’s VAT mini one-stop shop (MOSS) – far fewer than expected.

  • February 2015

    EU VAT rules causing thousands of businesses to close

    February 28, 2015

    A new report has shown that thousands of businesses across the EU are being forced into closure by the EU’s VAT rules governing the place of supply for e-services, introduced this year.

  • Walkers hires Jonathan Sheehan for Dublin office

    February 25, 2015

    Jonathan Sheehan has joined Walkers Ireland as a partner and head of the tax group in Dublin.

  • The Brockman brief: Interest: Double taxation equality is fading

    February 24, 2015

    In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislation to limit interest deductibility, the shift in focus from eliminating double taxation to eliminating non-taxation, and why, as a result, double taxation via interest limitations is here to stay.

  • Cheers! Celebrate the world's top transactional firms

    February 24, 2015

    International Tax Review analyses global M&A trends from the past year and highlights the leading firms for tax transactional advice by jurisdiction.

  • Ireland: ICAV – Ireland’s new corporate funds vehicle

    February 24, 2015

  • Looking to the future: Life after the ‘Double Irish’

    February 24, 2015

    Competitive tax regimes and tax-planning strategies have been increasingly in the spotlight over the past 18 months or so, and the international tax landscape is changing. Louise Kelly, tax partner at Deloitte, looks at recent tax changes and assesses how Ireland is positioned after the abolition of the infamous ‘Double Irish’.

  • Sino-Irish relations: China outbound investment guide

    February 24, 2015

    Caroline Devlin, partner at Arthur Cox, explains the features of the Irish tax and legal system which make it an attractive investment location, and looks specifically at Chinese outbound investment in this regard.

  • The European Tax Awards 2015: The entry period is now closed

    February 23, 2015

    The closing date for entries for the European Tax Awards 2015 has now passed.

  • Taxpayers emerge victorious from air travel tax dispute

    February 13, 2015

    Aer Lingus and Ryanair have won European Court of Justice (ECJ) cases against the European Commission concerning the Irish air travel tax (ATT).

  • Taxand Ireland partner gives ground-breaking input on Irish Finance Bill

    February 12, 2015

    A William Fry partner has participated in the pre-legislative scrutiny of the Finance (Tax Appeals Commission) Bill – the first time a tax practitioner has been invited to the process.

  • Deloitte Ireland adds three new tax partners

    February 04, 2015

    Deloitte Ireland has appointed three new tax partners: Louise Kelly, Tom Maguire and Pieter Burger.

  • January 2015

    BEPS – Preventing treaty abuse: A practical perspective

    January 27, 2015

    Keith Brockman, global tax director at Mars and author of the International Tax Best Practices blog, analyses BEPS Action 6 on preventing treaty abuse, calling for more balance in seeking to avoid double taxation and double non-taxation, and more guidance on the interplay between domestic law and treaty interaction.

  • Mariano Giralt: Global custodian and acronym-buster

    January 27, 2015

    The landscape of international taxation is changing. The OECD’s BEPS project is likely to rewrite the rules governing international taxation in a way that has not been seen since the League of Nations shaped existing rules in the 1920s. A key component of this is taxation of the financial sector. Various sector-specific tax laws have been proposed. This is providing those in the sector with plenty to think about. One such figure is Mariano Giralt, Managing Director, Tax Services, at BNY Mellon. He talks to Matthew Gilleard about some of the key tax developments impacting financial services.

  • In taxpayers' sights: What to look out for in 2015

    January 27, 2015

    With multilateral projects due for final delivery, and many of 2014’s key themes lingering on, 2015 comes with a lot of unfinished business.

  • Full plate for taxpayers seeking certainty in 2015

    January 27, 2015

    With multilateral projects reaching their climax in 2015, the year ahead is sure to be filled with moments that define the future direction of international taxation. Matthew Gilleard highlights some of the major trends taxpayers should be looking out for in 2015.

  • Indirect tax: Innovation, energy, and e-commerce

    January 27, 2015

    As global communications become more efficient, developing countries are fast-tracking their progress to becoming global economies – with VAT and excise tax reforms a crucial part of that process. Meredith McBride speaks with indirect tax leaders to pinpoint the issues that will have taxpayers and their advisers scratching their heads in 2015.

  • Moving goalposts mean taxpayers must stay on toes

    January 27, 2015

    Joe Stanley-Smith analyses how new attitudes and initiatives from tax authorities in key jurisdictions will influence the national and international tax dispute landscape in 2015.

  • Ireland: Consultation launched on Ireland’s Knowledge Development Box

    January 27, 2015

  • Moscovici rules out minimum VAT threshold

    January 23, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has ruled out implementing a minimum threshold for VAT paid on e-services, broadcasting and telecommunications.

  • Small businesses rail against VAT MOSS changes

    January 21, 2015

    Small and micro-businesses have spoken out against this year’s EU changes to the place of supply for e-services, telecommunications and broadcasting.

  • EU Parliament and Council agree on beneficial ownership registers

    January 07, 2015

    EU Parliament and Council negotiators have agreed a draft directive which would introduce beneficial ownership registers in Europe for the first time.

International Correspondents