Insights

With a significant number of employees now working in different locations, global mobility has become an area of focus for Ireland’s Revenue Commissioners. Revenue has increased their resources in this area and begun to issue detailed guidance that addresses employers and employees in these circumstances.

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On 22nd March 2021, the EU Council introduced "DAC7”, or the 7th Directive (2011/16/EU), on Administrative Cooperation, which enables EU Member States to address some of the perceived negative aspects of the digital economy, by extending the scope of existing exchange of information provisions between Member States, and thus ensuring greater transparency on cross border transactions.

The Companies (Corporate Enforcement Authority) Act 2021 contains a provision, which requires the directors of Irish companies to provide their Personal Public Service (PPS) numbers on certain documents submitted to the Companies Registration Office (CRO) in order to allow for verification of a director’s identify.

The Forum on Tax Administration, a member group of the OECD/G20 Inclusive Framework on BEPS (Base Erosion and Profit Shifting), along with other OECD task forces, published a guide to Multilateral Mutual Agreement Procedures multilateral (MAPs) and Advance Pricing Arrangements (APAs). This guide is abbreviated as the ‘MoMA’.

Finance Act 2022 introduced significant changes to the R&D tax credit regime. Most of the changes accommodate the OECD Pillar Two GloBE rules and therefore were expected. Some of the practical issues now arising were not foreseen. In this insight, we summarise the new R&D regime and highlight the key practical considerations for companies.

The European Parliament has published its approval of the European Commission’s draft proposal for Anti-Tax Avoidance Directive III (ATAD III) with recommended amendments.

The Digital Games Tax Credit aims to capitalise on the synergies with the established Irish film and animation sectors, and to support quality employment in creative and digital arts in Ireland.

With an increasing focus by Revenue on the correct operation of the Pay-As-You-Earn (PAYE) system, now is the time for businesses to review payroll and employment related taxes. By performing required regular check-ups on processes and systems, businesses can ensure that any potential risks are identified before problems arise and a PAYE risk review can help with this.

The European Commission held a public consultation in respect of a new proposed corporate tax system referred to as Business in Europe: Framework for Income Taxation (“BEFIT”). According to the Commission, the initiative aims to introduce a single corporate tax rulebook for the EU, based on a common tax base and allocation of taxable profits to Member States based on a pre-defined formula. Once allocated, the taxable profits would be subject to the corporate income tax rates of the relevant Member States.

The purpose of the R&D tax credit regime is to encourage both foreign and indigenous companies to undertake new or additional R&D activity in Ireland. It is a very valuable relief for qualifying companies.

Capital allowances are a form of tax relief for capital expenditure incurred on certain assets. Similar to depreciation, the relief is a write off of the expenditure over a certain period for certain assets in use for the purposes of the trade or rental business. Capital allowances reduce the income subject to tax. They are the only means of providing tax relief for capital expenditure incurred on both residential and commercial properties.