Factsheets

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.

The Court of Justice of the European Union (“CJEU”) recently handed down a judgement in the case of GE Aircraft Engine Services Ltd (C-607/20), concerning the VAT treatment of vouchers, offered to employees as incentives, as part of a rewards scheme.

The European Commission recently issued a proposal to amend the Directive on Administrative Cooperation (DAC) in the form of DAC8. The proposal extends the reporting obligations under the Directive to cover income or revenue streams generated from crypto-assets.

There have been a number of updates to the Temporary Business Energy Support Scheme (“TBESS”) in recent weeks. The updates mainly concern the administration of the scheme and are therefore the focus of this insight.

The Irish Revenue (“Revenue”) published updates to their tax and duty manual (“TDM”) containing guidelines for correlative adjustment (“CA”) claims under Ireland’s double tax treaty network. Read summary of the Revenue guidelines.

The Irish Government has introduced the Temporary Business Energy Support Scheme (“TBESS”) to provide support to businesses with their energy costs. This scheme, will be administered by the Irish Revenue, and intends to alleviate the pressures faced by businesses that are experiencing unprecedented increases in their electricity and gas costs.

In December 2021, the European Commission (EC) published its proposal for Anti-Tax Avoidance Directive III (ATAD III) which aims to discourage the misuse of shell companies within the EU.

This correspondence, deemed a Level 1 Compliance Intervention, offers all eligible taxpayers the opportunity to self-review their tax returns for Period 1 (which ended on 31 December 2021 or 30 April 2022 where extension applied) and make an unprompted qualifying disclosure by 31 January 2023 in relation to any additional tax liabilities identified.

The European Commission recently published a proposal for a new EU Directive creating a debt-equity bias reduction allowance (‘DEBRA’) and further limitation of the deductibility of interest for corporate tax purposes. This initiative is part of the “EU strategy on business taxation”.