Finance Act 2014 to end "double irish" tax structures
01 Jan 2015
The Finance Act 2014 was signed into law on 23 December 2014. The Act, among others, introduces amendments to the corporate tax residence rules designed to address concerns about the “double Irish” structure. The amendments provide that an Irish incorporated company will be regarded as Irish tax resident.
To ensure alignment with the treatment of company residence in double taxation agreements (DTAs), there is one exception to this incorporation rule. If, under the provisions of a DTA, an Irish-incorporated company is regarded as tax resident in another territory, the company will not be regarded as Irish tax resident. The amendments also clarify that a non-Irish-incorporated company that is managed and controlled in Ireland is not prevented from being regarded as Irish tax resident.
The new provisions have effect from 1 January 2015 for companies incorporated on or after 1 January 2015.
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Treatment and operation (Other)
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Inward FDI:
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