(October 14, 2014)

On October 14, 2014 the Irish Government published the Budget 2015 Fact Sheets. One of the Fact Sheets relates to Corporation Tax and is titled: “Road Map – Detailed Commitments and Actions”. Although the Roadmap contains 10 Commitments/Actions, we assume that most visitors of our website are especially interested in Commitment/Action 2: “Reputation: Company Residence Rules”.

The roadmap summarizes Commitment/Action 2 as follows: “ACTION 2: Legislative change on Ireland’s company residence rules introduced in Finance Bill 2014”. Regarding this Commitment/Action the Roadmap furthermore states:”

• Ireland’s company tax residence rules have not kept pace with international tax developments.
• They therefore will be updated in Finance Bill 2014 to provide a default rule that all companies incorporated in Ireland are tax resident in Ireland.
• The change will come into effect on 1 January 2015 in respect of new companies.
• In the interest of giving certainty to companies with existing operations in Ireland, a transition period to 2020 will be provided.”

The other 9 Commitments/Actions mentioned in the Roadmap are (the summary the roadmap provides of each Action is mentioned between the brackets): 

• Commitment/Action 1 – “Rate: maintaining the 12.5% corporation tax rate is settled policy, it will not change” (ACTION 1: Budget 2015 publication of independent ESRI Research in the Department’s “Economic Impact Assessment of Ireland’s Corporation Tax Policy”);
• Commitment/Action 3 – “Regime: Intellectual Property” (ACTION 3: Public consultation on “Knowledge Development Box” to open in 2014, and legislative enhancements to s.291A introduced in Finance Bill 2014);
• Commitment/Action 4 – “Regime: R&D tax credit” (ACTION 4: Legislative changes to R&D regime introduced in Finance Bill 2014);
• Commitment/Action 5 – “Regime: Special Assignee Relief Programme (SARP)” (ACTION 5: Legislative changes to SARP introduced in Finance Bill 2014);
• Commitment/Action 6 – “Regime: Employment and Investment Incentive (EII)” (ACTION 6: Legislative changes to EII introduced in Finance Bill 2014 of the R&D tax credit.);
• Commitment/Action 7 – “Regime: Continue to Diversify and Improve Access to new Export Markets” (ACTION 7: Legislative changes to FED regime introduced in Finance Bill 2014);
• Commitment/Action 8 – “Regime: Competent Authority for Transfer Pricing” (ACTION 8: Additional Competent Authority staff to be recruited);
• Commitment/Action 9 – “Reputation: Expansion of Tax Treaty Network” (ACTION 9: Work to expand Ireland’s DTA Network is continuing, and will be accelerated where possible);
• Commitment/Action 10 – “Reputation: Ireland is maintaining its commitment to ensuring an open and transparent tax regime” (ACTION 10: Publication of Spillover Analysis report and continued support of information exchange and reporting).

For further information click here to be forwarded to the Roadmap as published on the website of the Irish Ministry of Finance, which will open in a new window.

More Budget 2015 Fact Sheets and other information relating to Budget 2015 can be found on the website of the Irish Ministry of Finance.

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