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Minister’s Brief

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fully in line with the new OECD requirements in terms of both scope and standards. Handled<br />

well, this could modernise our regime with a minimal loss of competitiveness.<br />

A multi-lateral instrument is currently being discussed at OECD level, which will provide the<br />

basis for implementing the OECD changes across the international tax treaty network. This is<br />

to be ready for signature by end-year and you will need to take a decision at that stage about<br />

whether Ireland signs it (the expectation is that we would, subject to the exact details being<br />

worked out).<br />

At EU level, there are a number of EU directives which address many of the same issues: the<br />

anti-tax avoidance directive; a directive on country-by-country reporting which has already<br />

been agreed; and a directive on interest and royalty flows. In high level terms our priorities<br />

have been to ensure consistency with OECD BEPS and to fight against any attempt at EU level<br />

to introduce minimum effective taxation – the latter could undermine our 12.5% rate and<br />

encroach on Member State sovereignty. These issues are likely to feature on the Ecofin<br />

Council of Ministers agenda in the months ahead. In particular, the Anti-Tax Avoidance<br />

Directive will feature on the May Ecofin agenda and a decision will be needed as to what<br />

extent Ireland can support the proposal.<br />

Page 56 of 184

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