Ireland: Government releases second feedback statement implementing global minimum tax
On 27 July 2023, the Irish Government released second feedback statement on the transposition of the OECD Pillar Two global minimum tax rules in line with EU Council Directive 2022/2523 of 14 December 2022. The consultation period will run to close
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Ireland: Revenue issues guidelines on EU tax dispute resolution mechanisms
On 17 July 2023, the Irish Revenue issued eBrief No. 165/23 on European Union (EU) tax dispute resolution mechanisms. Accordingly, Tax and Duty Manual Part 35-02-10 - Guidelines on the European Union (Tax Dispute Resolution Mechanisms) Regulations
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Ireland: Revenue updates guidance on R&D tax credit
On 17 July 2023, the Irish Revenue issued eBrief No. 166/23 on research and development (R&D) corporation tax credit. Accordingly, Tax and Duty Manual Part 29-02-03 - Research and Development (R&D) Corporation Tax Credit - has
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Ireland: Revenue issues guidance for platform operators under DAC7
On 5 July 2023, the Irish Revenue issued eBrief No. 155/23, which provides guidance for platform operators for the exchange of information on income generated through digital platforms (DAC7). Council Directive 2011/16/EU (DAC) provides for the
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Ireland: Government to introduce temporary solidarity contribution to fossil fuel sector
On 23 June 2023, the Minister for the Environment, Climate and Communications, Mr. Eamon Ryan, announced the publication of the Energy (Windfall Gains in the Energy Sector) (Temporary Solidarity Contribution) Bill 2023. This Bill provides for a
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Ireland implements public country-by-country reporting directive
On 22 June 2023, the Irish Minister for Enterprise, Trade and Employment signed the European Union (Disclosure of income tax information by certain undertakings and branches) Regulations 2023 regarding the implementation of public country-by-country
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Ireland incorporates close company surcharge into corporation tax for preliminary tax calculation
On 7 June 2023, the Irish Revenue issued eBrief No. 139/23, which provides guidance regarding the incorporation of close company surcharges into the computation of corporation tax. Accordingly, Tax and Duty Manual Part 41A-07-02 - Payment of
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Ireland: Revenue provides guidance on foreign entity classification for Irish tax purposes
On 18 May 2023, the Irish Revenue issued eBrief No. 117/23 to provide guidance on classifying foreign entities for Irish tax purposes. Accordingly, Revenue provides Tax and Duty Manual (TDM) Part 35C-00-02 - Foreign Entity Classification For Irish
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Ireland: Government releases public consultation implementing global minimum tax
On 31 March 2023, the Irish Department of Finance published a public consultation document on the transposition of the OECD Pillar Two global minimum tax rules in line with EU Council Directive 2022/2523 of 14 December 2022. The consultation period
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Ireland: Revenue updates guidance for charges on income for corporation tax purposes
On 1 February 2023, the Irish Revenue issued eBrief No. 025/23 regarding charges on income for corporation tax purposes. Accordingly, Tax and Duty Manual Part 08-02-01 has been updated. The updates include the following sections: In section
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Ireland: Revenue updates guidance on CbC reporting
On 25 January 2023, the Irish Revenue issued eBrief No. 018/23 on country-by-country (CbC) reporting - data access & usage. Accordingly, Tax and Duty Manual Part 38-03-20 has been updated. In addition to editorial changes, amendments of note
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Irish revenue issued new guidance on interest limitation rules and foreign currencies
On 10 January 2024, the Irish Revenue released eBrief No. 014/24, which includes updated guidance (TDM 35D-01-01) related to the interest limitation rule (ILR). In accordance with Article 4 of ATAD, the ILR limits the interest deductibility of
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Ireland: President signs the Finance Bill 2022 into Law
On 15 December 2022, Michael D. Higgins, the President of Ireland signed the Finance Bill 2022 into Law. The Finance Act contains new tax measures including changes in corporate income tax and transfer pricing related measures. The main tax measures
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Ireland updates guidance on payment and receipt of interest and royalties without deduction of income tax
On 22 December 2022, the Irish Revenue published eBrief No. 221/22 on payment and receipt of interest and royalties without deduction of income tax. Accordingly, Tax and Duty Manual Part 08-03-06 - Payment and Receipt of Interest and Royalties
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Ireland proposes windfall profit tax in the energy sector
On 22 November, the Irish Minister for the Environment, Climate and Communications, Eamon Ryan announced measures to address windfall gains in the energy sector through the implementation of Council Regulation (EU) 2022/1854. Elevated wholesale
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Ireland explains non-resident corporate landlords within the charge to corporation tax
On 21 November 2022, the Irish Revenue published eBrief No. 199/22 clarifying that corporate landlords are subject to corporation tax rather than income tax on Irish rental income from 1 January 2022. Accordingly, the following Tax and Duty Manuals
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Ireland: Government publishes Finance Bill 2022
On 20 Oct 2022, Ireland’s Minister for Finance Paschal Donohoe published the Finance Bill 2022 as part of the Irish budget. The Finance Bill contains new tax measures that were not included in the budget presented in September 2022. The main tax
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Ireland: Revenue updates guide to exchange of information under DAC6
On 26 September 2022, the Irish Revenue published an eBrief No. 175/22 on Guide to Exchange of Information. Accordingly. Tax and Duty Manual Part 35-01-01a (the Guide) under Council Directive 2011/16/EU, Ireland’s double taxation agreements and
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