In this edition of the Maples Tax Update, we examine a number of current Irish and international tax issues. In the financial services section, we outline significant new Irish Revenue guidance on the tax treatment of "section 110 companies" and Irish real estate funds. We also comment on the tax treatment of Irish investment managers and examine the new EU directive on reporting aggressive tax structures, in addition to the EU's proposals for digital taxation and the tax status of REITs. Finally, in the corporate taxation section, we examine the recent tax advantaged "KEEP" option schemes and the treatment of share buy-backs.
The Irish Revenue published new technical guidance on 24 May 2018 relating to companies falling within the scope of section 110 of the Irish Taxes Consolidation Act 1997 (known as "section 110 companies").
Andrew Quinn and David Burke have contributed to the Ireland chapter of the Chambers Global Practice Guide to Corporate Tax 2018. This guide provides a practical overview of the tax and legal regime in Ireland.
The Irish Finance Act 2017 was signed into law by the Irish President on 25 December 2017. It introduces a number of important changes and enhancements to Irish tax law. This update summarises the main changes for Irish and international investors, companies and individuals.
Ireland is a leading location for the development, exploitation and management of intellectual property (IP). According to IDA Ireland, the number of global companies centralising their IP management in Ireland has made Ireland one of the largest exporters of IP in the world. One of the key drivers for this is the attractive tax regime, including the 12.5% corporation tax rate on trading income, a flexible 25% tax credit on the cost of eligible research and development activities, capital allowances on the cost of acquiring certain intangible assets and a large double tax treaty network to facilitate the flow of funds between Ireland and other countries. Ireland has signed double tax treaties with over 70 countries.