DAC6 Updates: Optional deferral of DAC6 reporting deadlines
On 24 June 2020, the European Council reached agreement on an optional 6-month postponement to the reporting deadlines for relevant taxpayers under EU Directive 2018/822 (DAC6), and a delay to the exchange of information under
See MoreIreland: Irish Revenue introduces new hybrid mismatch guide
On 8 July 2020, the Revenue published eBrief No. 137/20 on a new Tax and Duty Manual Part 35C-00-01, which provides an overview of the anti-hybrid rules that were introduced into Part 35C TCA 1997 by Finance Act 2019. This manual covers following
See MoreIreland: Revenue issues an eBrief regarding treatment of losses
On 25 June 2020, the Irish Revenue published an eBrief No. 124/20 on a Tax and Duty Manual part 19-02-05 related to treatment of capital losses. This manual describes the principles of allowable losses, and clarifies that where an allowable loss
See MoreIreland: Tax authority extends the DAC6 reporting timelines by six months
Due to coronavirus outbreak, the European Commission has recently agreed to delay the entry into force of certain European Union (EU) taxation measures. Among these is the delay of Council Directive 2018/822, commonly known as the Directive on
See MoreIreland: Revenue publishes guidelines on corresponding TP adjustments
On 24 April 2020, the Irish Revenue issued an eBrief No. 068/20 to announce about the publication of A new Tax and Duty Manual on corresponding transfer pricing (TP) adjustments. Guidelines for Article 9 Corresponding Adjustment claims This
See MoreIreland: Revenue announces tax measures and guidance due to COVID-19 pandemic
On 13 March 2020, the Revenue announced tax measures and guidance for small and medium enterprises (SMEs), other than SMEs, employees, and the self-employed who may be affected by the coronavirus crisis. The guidance includes: Small and medium
See MoreIreland: Tax Revenue publishes e-Brief No. 029/20 on “main benefit test” under DAC6 legislation
On 4 February 2020, the Tax Revenue published a manual, entitled “e-Brief No. 029/20”, relating to the “main benefit test. The manual has been updated to include a reference to the EU mandatory disclosure regime (DAC6), which comes into force
See MoreIreland: President signs Finance Bill 2019 into Law
On 22 December 2019, President, Michael D. Higgins, signed the 2019 Finance bill into law. This Finance Act 2019 implements the taxation changes announced on Budget, including new transfer pricing legislation, introducing some necessary
See MoreIreland: Revenue updates MAP guidance for BEPS MLI
The Revenue has recently released eBrief No. 223/19 entitled Tax and Duty Manual Part 35-02-08 on amended MAP guidelines to implement for the ratification of the multilateral convention to implement tax treaty related measures to prevent BEPS
See MoreIreland: Revenue publishes eBrief No. 202/19 regarding capital loss treatment
On 5th December 2019, the Irish Revenue Commissioners published eBrief No. 202/19 regarding guidance on the treatment of allowable losses for Capital Gains Tax (CGT) purposes. Under the eBrief No. 202/19, Tax and Duty Manual Part 19-02-05 has been
See MoreIreland: Revenue publishes eBrief No. 203/19 on dividend withholding tax
On 5 December 2019, Revenue published eBrief No. 203/19 regarding the public consultation reminder of Dividend Withholding Tax (DWT). On 8 October 2019, the Finance Minister, announced a new process for applying and collecting Dividend
See MoreIreland: Finance Minister publishes draft law regarding mandatory disclosure rules
On 17 October 2019, the Finance Minister published draft legislation as part of Finance Bill 2019 for the implementation of European Union (EU) Directive 2018/822 regarding mandatory disclosure and exchange of cross-border tax arrangements (DAC6)
See MoreIreland: Finance Minister announces Finance bill for the year 2020
On 16 October 2019, the Finance Minister, Paschal Donohoe TD, announced Cabinet approval for the publication of the Finance Bill 2019. It was published on 17 October 2019. The Bill sets out the legislative provisions to bring effect to the tax
See MoreIreland: Tax authority publishes a manual on MLI Tie-Breaker Rule
On October 9, 2019, the tax authorities published a guide that describes the way of how the new rule regarding the determination of treaty residence of dual-resident companies applies under the Multilateral Convention to Implement Tax Treaty
See MoreIreland: Govt. announces draft budget 2020
On 8 October 2019, Govt. announced draft Budget 2020. This draft Budget introduced some amendments in respect of corporate income tax, transfer pricing, dividend withholding tax, personal income tax, small and medium enterprises (SMEs),
See MoreIreland: Finance Ministry issues Budget 2020 strategy
On 11 September 2019, the Minister for Finance and Public Expenditure and Reform issued Budget 2020 strategy. It will be delivered at a time of unprecedented uncertainty but it will be delivered from a position of
See MoreIreland: Finance Department publishes feedback statement regarding TP rules
In February 2019, the Finance Department carried out a public consultation on Ireland’s transfer pricing rules indicating the intended direction in respect of certain recommendations contained in the Coffey Review and seeking stakeholders
See MoreIreland introduces EU Directive on Dispute Resolution
Ireland has issued Statutory Instrument (S.I.) No. 306/2019 of 5 July 2019, that includes regulations for the purpose of giving effect to Council Directive (EU) 2017/1852 of 10 October 2017 on dispute resolution. The Directive
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