ey-global-tax-policy-outlook-for-2015

Ireland
2.9 Country position on OECD Base Erosion
and Prot Shifting (BEPS) Action Plan
•
Ireland’s International Tax Strategy. This strategy document
transparent and that all rules are clearly set down in national
solution to combat tax evasion through active participation
that: “Ireland is taking an active part in the BEPS project and
address aggressive international tax planning.”
• In May 2014, the Minister for Finance launched a public
2014, the results of this consultation were published by the
OECD Base Erosion and
; this document also
explores the potential impact of the actions on Ireland and
Ireland’s tax regime.
•
A Road Map for Ireland’s Tax Competitiveness, which ‘’builds
setting out a roadmap for Ireland’s tax competitiveness now
and into the future. The document also provides an update
on the objectives set out in the International Tax Strategy.
2.10 Pending tax proposals
• Company residence: Budget 2015 proposed that all Irish
incorporated companies will be regarded as Irish resident
subject to an override within a double taxation treaty.
This rule will apply from 1 January 2015 for companies
incorporated on or after 1 January 2015. For companies
incorporated before 1 January 2015, the new rule will apply
from the earlier of 1 January 2021 or from a date on or
after 1 January 2015 where there is a change in ownership
after, there is a major change in the nature or conduct of the
business of the company.
•
• Intangible assets: removal of 80% cap on the annual
assets.
• Knowledge development box: plan announced to introduce
allow.
• Start-up operations: extension of three-year tax relief to
companies commencing operations in 2015.
•
equipment: extended to 2017.
•
travel to Japan, Singapore, South Korea, the UAE, Qatar,
Mexico and Malaysia. Number of days required to be spent
abroad reduced to 40 with travel time being included.
• Special Assignee Relief Programme (SARP): relief extended
for a further three years until the end of 2017. Further
enhancements include the removal of the upper salary
threshold of €500,000.
•
2014.
• Film corporation tax credit: minimum eligible expenditure is
being reduced from €200,000 to €125,0000.
• Agri-taxation: a number of agri-taxation measures are
proposed.
106 | The outlook for global tax policy in 2015