Global Tax 50 2017: Seamus Coffey

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Global Tax 50 2017: Seamus Coffey

Seamus Coffey

Seamus Coffey is a new entry this year

Seamus Coffey is a new entry in this year's Global Tax 50, and makes the cut for his extensive review of Ireland's corporation tax code.

In the review, 'Review of Ireland's Corporation Tax Code' (or, informally, the Coffey report) he sets out a number of recommendations for modernising Ireland's transfer pricing (TP) rules, recalibrating the existing intellectual property (IP) regime and maintaining Ireland's competitiveness. The report is expected to have a significant impact on transfer pricing in Ireland in the coming years.

Coffey, a lecturer in economics at University College Cork and chairman of the Irish Fiscal Advisory Council, was appointed by Ireland's Department of Finance in October 2016 and tasked with finding areas of the Irish tax code that needed updating.

The report is not legally binding but, if adopted, the recommendations will have a big impact on the application of TP rules. It proposes expanding the scope of application of the TP rules and imposing a heavier administrative burden on taxpayers subject to the rules.

In his report, Coffey confirmed that the Irish corporation tax code is fair, competitive, sustainable and certain. However, in order to modernise the TP rules, the report recommended Ireland follow the 2017 OECD TP guidelines and adopt BEPS Action 13 on country-by-country reporting. It also recommended that TP rules should apply to all transactions including non-trading transactions, capital transactions and SME transactions.

The report made recommendations on taxation of intangible assets, saying that a controlled foreign company regime must be introduced by 2019 in line with the EU's Anti-Tax Avoidance Directive. Coffey also called for Ireland to maintain its commitment to BEPS and EU initiatives, and recommends that Ireland moves to a territorial tax system and/or changes its foreign tax credit regime. This would help maintain Ireland's competitiveness, the report said.

The Minister for Finance Paschal Donohoe stated the review "provides a clear road map and timeframe for Ireland to implement important international reforms".

Something that will not be altered following the report is Ireland's 12.5% corporate tax rate, which, according to Donohoe, remains "the bedrock of our competitive corporation tax regime and that is not going to change".

The Global Tax 50 2017

View the full list and introduction

The top 10 • Ranked in order of influence

1. US Tax Reform Big 6

2. Dawn of the robots

3. The breakdown of global consensus

4. The fifth estate

5. Margrethe Vestager

6. Arun Jaitley

7. Sri Mulyani Indrawati

8. Pascal Saint-Amans and Achim Pross

9. Richard Murphy

10. Cristiano Ronaldo and Lionel Messi

The remaining 40 • In alphabetic order

Tomas Balco

Piet Battiau

Monica Bhatia

Blockchain

Rasmus Corlin Christensen

Seamus Coffey

Jeremy Corbyn

Rufino de la Rosa

Fabio De Masi

The Estonian presidency of the Council of the European Union

Maria Teresa Fabregas Fernandez

The fat tax

Maya Forstater

Babatunde Fowler

The GE/PwC outsourcing deal

The Gulf Cooperation Council (GCC)

International Consortium of Investigative Journalists (ICIJ)

Meg Hillier

Chris Jordan

Wang Jun

James Karanja

Bruno Le Maire

John Pombe Joseph Magufuli

Cecilia Malmström

The Maltese presidency of the EU Council

Paige Marvel

Theresa May

Angela Merkel

Narendra Modi

Pierre Moscovici

The European Parliament Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA)

The Paris Agreement

Grace Perez-Navarro

Alexandra Readhead

Heather Self

TaxCOOP

Tax Justice Network

Donald Trump

United Nations Committee of Experts on International Cooperation in Tax Matters

WU Global Tax Policy Center

more across site & shared bottom lb ros

More from across our site

Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International
In the first of a new series of weekly opinion pieces, ITR Editor Tom Baker reflects on the OECD’s attempts to sanitise the US’s brazen pillar two negotiations
The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
The global minimum tax deal is not viable without US participation, Friedrich Merz has argued
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations
Gift this article