European Union: Irish Revenue Reports Reflect Strengthening Commercial Environment

Last Updated: 25 July 2018
Article by Joe Duffy and Tomás Bailey

The Irish Revenue Commissioners (Revenue) recently published their 2018 annual report together with an analysis of corporation tax receipts for 2016 and 2017 (the Reports). The Reports reflect Ireland's strengthening commercial and economic environment and highlight the continued attractiveness of Ireland's competitive, robust, BEPS-compliant and transparent tax system. The Reports also provide further empirical evidence of the impact international tax developments are having on taxpayers with cross-border operations.

IP and Innovation

The Reports indicate that Ireland remains an attractive destination for the development and exploitation of intangibles noting that in 2016:

  • Claims for capital allowances in respect of the amortisation of intangibles further increased to €36 billion ($42 billion) (interestingly, the increase in claims for capital allowances in respect of tangible assets was even greater); and
  • A total of € 1.8 billion of qualifying R&D expenditure was incurred by 1,486 companies claiming Ireland's refundable R&D tax credit.

The Reports note that Ireland's knowledge development box (the world's first BEPS compliant patent box) has not been widely claimed by taxpayers to date. The Reports indicate that this position is expected to change over the coming years as taxpayers develop and implement the procedural processes required to accurately track and trace income and expenditure.

International Affairs

The Reports highlight Revenue's continued commitment to efficient dispute resolution despite the post-BEPS increase in mutual agreement procedure (MAP) and advance pricing agreement (APA) requests Revenue have experienced.

During 2017, Revenue's engagement with other competent authorities through MAP resulted in the conclusion of 12 cases, 11 of which related to transfer pricing. The cases concluded during 2017 represent almost 30% of Revenue's opening inventory for the year. Revenue also held negotiations on bilateral APAs with other competent authorities during 2017 to successfully negotiate two new APAs. In total, eight new APA requests were received by Revenue during the year.

The Reports also note Revenue's active involvement in the inter-departmental work being undertaken to assess and prepare for the potential impact of Brexit in Ireland. Revenue are primarily focused on the fair and efficient implementation of possible tax and customs outcomes post-Brexit. Revenue's activities in this context are likely to increase over the coming year as the details of the UK's post-Brexit relationship with the EU become clearer.

Enhanced Cooperation and Certainty

In line with international best practices, Revenue have sought to promote a policy of cooperative compliance with large taxpayers by relaunching the cooperative compliance framework (CCF) in 2017 to encourage increased levels of voluntary compliance and certainty across all taxes and duties. The Reports highlight the success of the CCF, noting that 77 corporate groups have elected to participate to date.

Date Overload?

The Reports highlight Revenue's increasing use of data for risk assessment purposes and note that in 2017 Revenue began evaluating and applying data received from other tax administrations under exchange of information programmes. The Reports indicate that this practice will become increasingly common during 2018.

The Reports also note Revenue's active role in the OECD Forum on Tax Administration Advances Analytics Network, noting that Revenue hosted a two day international conference on advanced analytic techniques in tax administration during 2017 which was attended by 47 delegates from 25 tax administrations.

The Reports indicate that Ireland is among the most transparent countries in the world based on the results of OECD peer reviews. Ireland's programme for exchanging tax rulings is fully operational and compliant with the OECD and EU requirements. The Reports confirm that of the 316 opinions issued by Revenue in 2017, 32 were exchanged under the EU and OECD programmes.

Tax Receipts

The Reports include an analysis of 2017 corporation tax payments and 2016 corporation tax returns which reflect Ireland's strong economic performance in recent years. The Reports confirm that tax receipts increased in 2017 across all tax heads, a trend which has continued into 2018.

The Reports also highlight that company trading profits in most major sectors increased, particularly in the manufacturing sector which recorded the largest sectoral trading profits for the year. Company employment figures also increased in this period to 1.9 million resulting in EUR 16 billion in income tax and social security receipts for the period.


The Reports suggest that the implementation of international tax policy developments have enhanced Ireland's appeal as a location for companies with cross-border operations to do business in and from. The foundation of Ireland's appeal in this context is the real substance on offer and the well-established multi-national business eco-system. The increased recruitment and investment in Ireland by such taxpayers is proof of this. The Reports indicate that Ireland's appeal in this context is underpinned by a tax authority which is willing to engage in a cooperative manner to provide taxpayers with the certainty required to carry on international business and to defend the Irish tax base where necessary.

Originally published by TP Week on Tuesday, 26 June 2018.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on

Click to Login as an existing user or Register so you can print this article.

In association with
Related Topics
Related Articles
Up-coming Events Search
Font Size:
Mondaq on Twitter
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
Email Address
Company Name
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Registration (you must scroll down to set your data preferences)

Mondaq Ltd requires you to register and provide information that personally identifies you, including your content preferences, for three primary purposes (full details of Mondaq’s use of your personal data can be found in our Privacy and Cookies Notice):

  • To allow you to personalize the Mondaq websites you are visiting to show content ("Content") relevant to your interests.
  • To enable features such as password reminder, news alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our content providers ("Contributors") who contribute Content for free for your use.

Mondaq hopes that our registered users will support us in maintaining our free to view business model by consenting to our use of your personal data as described below.

Mondaq has a "free to view" business model. Our services are paid for by Contributors in exchange for Mondaq providing them with access to information about who accesses their content. Once personal data is transferred to our Contributors they become a data controller of this personal data. They use it to measure the response that their articles are receiving, as a form of market research. They may also use it to provide Mondaq users with information about their products and services.

Details of each Contributor to which your personal data will be transferred is clearly stated within the Content that you access. For full details of how this Contributor will use your personal data, you should review the Contributor’s own Privacy Notice.

Please indicate your preference below:

Yes, I am happy to support Mondaq in maintaining its free to view business model by agreeing to allow Mondaq to share my personal data with Contributors whose Content I access
No, I do not want Mondaq to share my personal data with Contributors

Also please let us know whether you are happy to receive communications promoting products and services offered by Mondaq:

Yes, I am happy to received promotional communications from Mondaq
No, please do not send me promotional communications from Mondaq
Terms & Conditions (the Website) is owned and managed by Mondaq Ltd (Mondaq). Mondaq grants you a non-exclusive, revocable licence to access the Website and associated services, such as the Mondaq News Alerts (Services), subject to and in consideration of your compliance with the following terms and conditions of use (Terms). Your use of the Website and/or Services constitutes your agreement to the Terms. Mondaq may terminate your use of the Website and Services if you are in breach of these Terms or if Mondaq decides to terminate the licence granted hereunder for any reason whatsoever.

Use of

To Use you must be: eighteen (18) years old or over; legally capable of entering into binding contracts; and not in any way prohibited by the applicable law to enter into these Terms in the jurisdiction which you are currently located.

You may use the Website as an unregistered user, however, you are required to register as a user if you wish to read the full text of the Content or to receive the Services.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these Terms or with the prior written consent of Mondaq. You may not use electronic or other means to extract details or information from the Content. Nor shall you extract information about users or Contributors in order to offer them any services or products.

In your use of the Website and/or Services you shall: comply with all applicable laws, regulations, directives and legislations which apply to your Use of the Website and/or Services in whatever country you are physically located including without limitation any and all consumer law, export control laws and regulations; provide to us true, correct and accurate information and promptly inform us in the event that any information that you have provided to us changes or becomes inaccurate; notify Mondaq immediately of any circumstances where you have reason to believe that any Intellectual Property Rights or any other rights of any third party may have been infringed; co-operate with reasonable security or other checks or requests for information made by Mondaq from time to time; and at all times be fully liable for the breach of any of these Terms by a third party using your login details to access the Website and/or Services

however, you shall not: do anything likely to impair, interfere with or damage or cause harm or distress to any persons, or the network; do anything that will infringe any Intellectual Property Rights or other rights of Mondaq or any third party; or use the Website, Services and/or Content otherwise than in accordance with these Terms; use any trade marks or service marks of Mondaq or the Contributors, or do anything which may be seen to take unfair advantage of the reputation and goodwill of Mondaq or the Contributors, or the Website, Services and/or Content.

Mondaq reserves the right, in its sole discretion, to take any action that it deems necessary and appropriate in the event it considers that there is a breach or threatened breach of the Terms.

Mondaq’s Rights and Obligations

Unless otherwise expressly set out to the contrary, nothing in these Terms shall serve to transfer from Mondaq to you, any Intellectual Property Rights owned by and/or licensed to Mondaq and all rights, title and interest in and to such Intellectual Property Rights will remain exclusively with Mondaq and/or its licensors.

Mondaq shall use its reasonable endeavours to make the Website and Services available to you at all times, but we cannot guarantee an uninterrupted and fault free service.

Mondaq reserves the right to make changes to the services and/or the Website or part thereof, from time to time, and we may add, remove, modify and/or vary any elements of features and functionalities of the Website or the services.

Mondaq also reserves the right from time to time to monitor your Use of the Website and/or services.


The Content is general information only. It is not intended to constitute legal advice or seek to be the complete and comprehensive statement of the law, nor is it intended to address your specific requirements or provide advice on which reliance should be placed. Mondaq and/or its Contributors and other suppliers make no representations about the suitability of the information contained in the Content for any purpose. All Content provided "as is" without warranty of any kind. Mondaq and/or its Contributors and other suppliers hereby exclude and disclaim all representations, warranties or guarantees with regard to the Content, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. To the maximum extent permitted by law, Mondaq expressly excludes all representations, warranties, obligations, and liabilities arising out of or in connection with all Content. In no event shall Mondaq and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use of the Content or performance of Mondaq’s Services.


Mondaq may alter or amend these Terms by amending them on the Website. By continuing to Use the Services and/or the Website after such amendment, you will be deemed to have accepted any amendment to these Terms.

These Terms shall be governed by and construed in accordance with the laws of England and Wales and you irrevocably submit to the exclusive jurisdiction of the courts of England and Wales to settle any dispute which may arise out of or in connection with these Terms. If you live outside the United Kingdom, English law shall apply only to the extent that English law shall not deprive you of any legal protection accorded in accordance with the law of the place where you are habitually resident ("Local Law"). In the event English law deprives you of any legal protection which is accorded to you under Local Law, then these terms shall be governed by Local Law and any dispute or claim arising out of or in connection with these Terms shall be subject to the non-exclusive jurisdiction of the courts where you are habitually resident.

You may print and keep a copy of these Terms, which form the entire agreement between you and Mondaq and supersede any other communications or advertising in respect of the Service and/or the Website.

No delay in exercising or non-exercise by you and/or Mondaq of any of its rights under or in connection with these Terms shall operate as a waiver or release of each of your or Mondaq’s right. Rather, any such waiver or release must be specifically granted in writing signed by the party granting it.

If any part of these Terms is held unenforceable, that part shall be enforced to the maximum extent permissible so as to give effect to the intent of the parties, and the Terms shall continue in full force and effect.

Mondaq shall not incur any liability to you on account of any loss or damage resulting from any delay or failure to perform all or any part of these Terms if such delay or failure is caused, in whole or in part, by events, occurrences, or causes beyond the control of Mondaq. Such events, occurrences or causes will include, without limitation, acts of God, strikes, lockouts, server and network failure, riots, acts of war, earthquakes, fire and explosions.

By clicking Register you state you have read and agree to our Terms and Conditions