Ireland: Tax Treaties

The European Commission's DAC Recast proposal introduces sweeping changes to cross-border tax reporting obligations, including a significant carve-out for multinational groups subject to Pillar Two's 15% minimum tax rate. With the removal of generic Category A hallmarks and extended reporting deadlines, the reforms promise over €1 billion in annual compliance savings while maintaining robust anti-avoidance protections. How will these targeted simplifications reshape the landscape of mandatory disclosu

The European Commission has adopted a comprehensive Tax Simplification Package aimed at reducing administrative burdens and enhancing competitiveness for businesses operating across the EU. This package consolidates existing tax directives and introduces significant reforms to interest limitation rules, controlled foreign company provisions, and withholding tax exemptions, while establishing new minimum standards for R&D tax treatment to align the EU more closely with major trading partners.

Irish Revenue's 2025 Annual Report reveals a tax authority increasingly leveraging data analytics and AI to enhance compliance enforcement, with significant activity in transfer pricing audits and tax avoidance cases. The report provides critical insights into Revenue's evolving technological capabilities and enforcement priorities that taxpayers and advisers need to understand.

The European Commission Decision concerned an exemption within the UK CFC rules known as the ‘group financing exemption'. Under the UK CFC rules, a CFC charge applies...

The EU Directive on Faster and Safer Relief of Excess Withholding Taxes (the "FASTER Directive") was approved at the May meeting of the Economic and Financial Affairs Council ("ECOFIN").

On 8 May 2024, Matheson made a submission responding to a public consultation on the design of an Irish participation exemption.

In this update, we summarise what tax and employment considerations Irish employers should be aware of where employees are working or wish to work in a country other than Ireland,

Financing structures involving Irish entities often employ the use of a special purpose vehicle ("SPV") which is a company established specifically to hold title to the aircraft subject to the...

The Irish Revenue Commissioners ("Revenue") have recently published a new tax and duty manual containing guidelines for correlative adjustment claims under Ireland's double tax treaty network ("CA Guidance").