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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 62. Dawn of the robots
3. The breakdown of global consensus4. The fifth estate
5. Margrethe Vestager6. Arun Jaitley
7. Sri Mulyani Indrawati8. Pascal Saint-Amans and Achim Pross
9. Richard Murphy10. Cristiano Ronaldo and Lionel Messi
The remaining 40 • In alphabetic order
Tomas BalcoPiet Battiau
Monica Bhatia Blockchain
Rasmus Corlin ChristensenSeamus Coffey
Jeremy CorbynRufino de la Rosa
Fabio De Masi The Estonian presidency of the Council of the European Union
Maria Teresa Fabregas Fernandez The fat tax
Maya ForstaterBabatunde Fowler
The GE/PwC outsourcing deal The Gulf Cooperation Council (GCC)
International Consortium of Investigative Journalists (ICIJ)Meg Hillier
Chris JordanWang Jun
James KaranjaBruno Le Maire
John Pombe Joseph MagufuliCecilia Malmström
The Maltese presidency of the EU CouncilPaige Marvel
Theresa MayAngela Merkel
Narendra ModiPierre Moscovici
The European Parliament Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) The Paris Agreement
Grace Perez-NavarroAlexandra Readhead
Heather Self TaxCOOP
Tax Justice NetworkDonald Trump
United Nations Committee of Experts on International Cooperation in Tax Matters WU Global Tax Policy Center

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