Firm

On October 9 2018, Ireland's Minister for Finance, Public Expenditure and Reform Paschal Donohoe announced budget 2019. On October 18 2018, the draft legislation to implement the budget was published. In furtherance of Ireland's obligations under the EU Anti-Tax Avoidance Directive (ATAD), Donohoe announced the introduction of a new controlled foreign companies (CFC) regime and an ATAD-compliant exit charge. The exit charge took effect from October 10 2018 and the CFC rules will apply to accounting periods beginning on or after January 1 2019.

Tax transparency and governance has moved up in the hierarchy of key topics and risks for the C-suite to monitor and manage. Tax has changed from simply just being in the exclusive realm of the tax director and being a compliance concern for multinationals, to becoming the more consequential strategic matter it is today. How you communicate on where and how you pay your taxes, and what your narrative is in terms of tax strategy and corporate social responsibility, has become increasingly important. This is due to the large increase in tax transparency requirements that have been mandated at international, EU and national levels. This trend started in 2012 and has intensified since revelations such as 'LuxLeaks', as well as the Panama and Paradise Papers. However, there are still quite a few CEOs, CFOs and tax directors – as well as tax advisors and others – who expect that the current transparency drive will soon blow over post-BEPS. So which one is it for tax transparency? Are we at the beginning of the end, or at the end of the beginning?

On November 2 2018, Hong Kong's new research and development (R&D) regime was enacted and applies to eligible expenditure incurred on or after April 1 2018.