Factsheets

Throughout 2023, the OECD Inclusive Framework has continued its work on the development of the Pillar Two Global anti-Base Erosion Rules in advance of the introduction of the rules on 31 December 2023.

Employment Tax Updates covering: Enhanced Reporting Requirements (ERR), Small Benefit Exemption, Shares Options – Revenue’s Compliance Focus and PAYE Revenue Audits

Finance Act 2022 introduced the requirement for employers to notify Revenue of certain payments made to employees known as ‘reportable benefits’. The introduction of this reporting requirement is subject to a commencement order; however, the target implementation date is 1 January 2024.

The introduction of Pillar Two brings unprecedented changes to the international tax landscape, the likes of which haven’t been seen for decades. The rules will create a fundamental shift in the way certain groups are taxed as well as an additional global compliance and reporting obligation for those within scope of the rules.

The Revenue Commissioners (“Revenue”) first introduced the Special Assignee Relief Programme (SARP) in 2012 as a method for encouraging companies to relocate or assign their key employees to work in Ireland. Where certain conditions are satisfied, 30 percent of taxable employment income over €100,000 is disregarded for income tax purposes. This programme can result in significant tax savings for key employees.

The Temporary Business Energy Support Scheme (TBESS) is extended until the end of April 2023. The monthly limit on payments that can be made under the scheme is enhanced. These changes featured in the Government’s Cost of Living package of supports announced in February 2023.

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.

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 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.