Angela Fleming, Partner and Head of Financial Services Tax, explores how simplifying the complex foreign tax credit rules in Schedule 24, TCA 1997 by aligning a single set of rules for all trading income, extending full pooling relief across treaty and non-treaty sources, and allowing excess credits to be carried forward or taken as a current-year trading deduction.
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In addition, Angela Fleming, highlights the need to enhance Ireland’s Section 110 regime by addressing the treatment of foreign withholding taxes to preserve tax neutrality, and by refining the consequences of inadvertent breaches of qualifying conditions, including the 8-week notification requirement and the €10 million de minimis test.
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Ian Clarke, Partner and Head of Transfer Pricing, considers how Ireland should avoid expanding transfer pricing rules to medium sized companies in order to reduce compliance costs for businesses. He explores developments across the EU and OECD initiatives, and highlights practical measures that could improve certainty, consistency and administrative efficiency for taxpayers.