On April 5, 2024 the Irish Department of Finance opened a public consultation on a strawman proposal* to introduce a participation exemption for foreign dividends. The proposed participation exemption will provide an exemption from corporation tax in respect of qualifying dividends received from foreign subsidiaries in accounting periods commencing on or after January 1, 2025.

The consultation period ran from April 5, 2024 to the close of business on May 8, 2024.

On June 21, 2024 the Irish Department of Finance published the following 20 responses it received to the Feedback Statement that it released with respect to the strawman proposal:

1. The response from the Alternative Investment Management Association (AIMA);
2. The response from A&L Goodbody LLP;
3. The response from the American Chamber of Commerce Ireland;
4. The response from Andersen:
5. The joined response from Aptiv plc, Eaton Corporation plc, Johnson Controls lnternational plc and Medtronic;
6. The response from Arthur Cox LLP;
7. The response from the Consultive Committee of Acountancy Bodies-Ireland (CCAB-I);
8. The response from Deloitte Ireland LLP;
9. The response from Ernst & Young;
10. The response from Grant Thornton Financial & Taxation Consultants Limited;
11. The response from Ibec;
12. The response from Insurance Ireland;
13. The response from Irish Funds;
14. The response from the Irish Tax Institute (the ITI);
15. The response from Kenmare Resources Plc;
16. The response from KPMG;
17. The response from Maples and Calder (Ireland) LLP;
18. The response from Matheson LLP;
19. The response from PWC; and
20. The response from the Irish Debt Securities Association;

*   A straw-man/strawman (or straw-dog) proposal is a brainstormed simple draft proposal intended to generate discussion of its disadvantages and to spur the generation of new and better proposals.

Copyright – internationaltaxplaza.info

Follow International Tax Plaza on Twitter (@IntTaxPlaza)