On 5 September 2018, the Minister for Finance and Public Expenditure & Reform, Paschal Donohoe T.D., has published Ireland’s Corporation Tax Roadmap. The Roadmap takes stock of the changing international tax environment, outlines the actions Ireland has taken to date and the further actions that will be taken over the coming years.

The Roadmap includes consideration of responses received to the Department’s consultation on the recommendations made in the Review of Ireland’s Corporation Tax Code, undertaken by Mr. Seamus Coffey, and the implementation of the Anti-Tax Avoidance Directives.

Transfer pricing rules

Ireland intends to update its transfer pricing rules, introducing new provisions in Finance Bill 2019 that would take effect from January 1, 2020, the roadmap states. This timeline is earlier than the year-end 2020 timeline proposed in an influential 2017 consultation undertaken by commissioned expert, Seamus Coffey.

CFC rules

The tax roadmap also indicates that legislation would be introduced in Finance Bill 2018 to add controlled foreign company (CFC) rules with effect from January 1, 2019, to comply with the ATAD.

Anti-hybrid rules

Anti-hybrid legislation will be introduced in Finance Bill 2019, the roadmap announced. A consultation paper on these rules will be issued in the 3rd quarter of 2018. Anti-reverse hybrid legislation will be introduced in a later finance bill.

Interest Restrictions

Ireland believes that its interest limitation rules are as effective to those required by the ATAD and will thus seek a derogation to defer implementation of the ATAD interest limitation rules until either 2024 or until such rules become a BEPS minimum standard.