Ireland: Updates for Implementing EU and OECD Exchange of Information Requirements

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On 2 February 2017, Revenue published eBrief 12/17, which explains the updates introduced in the tax and duty manual regarding exchange of information requirements in respect of tax rulings. The key updates are following:

  1. Section 1 of the tax and duty manual has been updated to reflect the fact that the EU Directive has been transposed into Irish law.
  2. Paragraph 6 of section 2.1, which provided details in relation to the optional exception that applied to the look-back element of the EU Directive, has been deleted as it is not relevant.
  3. Section 3.1, paragraph 2, bullet point 3 has been updated to reflect the fact that unilateral downward adjustments made by taxpayers under informal capital contribution or excess profit regimes should not arise under Irish tax law.
  4. Sections 3.3 has been updated to reflect the fact that rulings were due to be exchanged under the look-back element of the OECD framework by 31 December 2016 and section 4.3 has been updated to reflect the fact that Revenue has exchanged opinions under the look-back element of the OECD framework.
  5. The references to Revenue guidelines on the provision of opinions in sections 4.1 and 4.5 have been updated as appropriate.
  6. Contact details in section 4.8 have been updated.
  7. The list of countries in Annex 3 has been updated to reflect the fact that additional countries have joined the Inclusive Framework under the Base Erosion and Profit Shifting Project.

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