Financial Services Tax Newsletter May 2025

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Welcome to the latest edition of the BDO Financial Services Tax Newsletter, where we bring you key updates and insights on tax developments within the Financial Services industry

Among a number of relevant topics, this issue features an analysis by our colleague Michelle Adams on the recent High Court decision in the Susquehanna case and its relevance for US LLCs and double tax agreements. 

Katie Auld, our Transfer Pricing Director, offers timely insights on Revenue’s increased focus on Transfer Pricing documentation, while we also explore recent updates to DAC 9 and the Undertaxed Profits Rule under Pillar Two.

Finally, with US-imposed tariffs top of mind, our VAT and Customs teams provide guidance on the potential impact for Irish exporters and practical steps to take.

We hope you find this publication informative. If you’d like to discuss any of the topics in further detail, the team and I would be happy to help.


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Irish Tax Monitor - April: The new era of Tariffs

With tariffs now on the global agenda in a way not seen for almost a century, there are risk assessment processes that Irish multinational corporates should be undertaking. We are currently in a “temporary pause” of sorts, in relation to escalating reciprocal tariffs. However, action is still advised.

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Irish Tax Monitor - March: High Court Susquehanna Case

The long anticipated High Court judgement in the Susquehanna case was given on the 2nd October 2024. Revenue denied the group relief claim on €46.6m of losses incurred in 2010/12. We explain the basis of this decision.

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Indian Tax Developments impacting Irish Aircraft leasing entities

Indian tax authorities have increased their focus on Irish entities undertaking aircraft leasing to Indian entities, with notices issued to some aircraft leasing companies, questioning the eligibility under the India-Ireland treaty.

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BDO Global Corporate Tax News | Issue 73, February 2025

BDO’s Global Corporate Tax News highlights key international developments in corporate and cross-border taxation. This issue focuses heavily on Pillar Two implementation, with new legislation enacted in multiple jurisdictions and the U.S. exiting the global agreement. Also featured are significant reforms in India, Germany, Greece, and Denmark.

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Irish Tax Monitor - March: Under Taxed Profits Rule

Pascal Saint-Amans, the former Director at the OECD Centre for Tax Policy and Administration who during his time at the OECD spearheaded the BEPS negotiations recently commented that 'if we remove the UTPR we no longer have a global minimum tax' when discussing the Trump Administration's opposition to the rule. Discover its implications.

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Irish Tax Monitor - March: Revenue's €748M Transfer Pricing Crackdown

Between 2015 - 2023, the Revenue Commissioners initiated 58 transfer pricing compliance interventions. Of the 33 finalised interventions, €748M was yielded. Approximately €233M of this amount was due to interest and penalties, while a restriction in trading losses of €952M represents a corporate tax impact of €119M. 

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Irish Tax Monitor - April: Tax Cooperation

The ECOFIN arrived at a political agreement on a proposal, amending the DAC9. This aims to reduce the compliance burden for companies arising under the Pillar Two Directive by enabling MNEs to file one centralised top-up tax information return for the entire group.

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BDO Global Transfer Pricing News | Issue 50, March 2025

Recently, tariffs and customs issues are dominating conversations in the international tax arena. For transfer pricing practitioners, customs discussions prompt thoughts of valuation, which can differ for customs and transfer pricing purposes.

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Business Post: Tax concerns are a crucial element in wealth management and exit strategies

While tax considerations are important for individuals looking to optimise wealth, they are more so when planning a business exit - Cian O'Sullivan, Private Client Tax.

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Newstalk Podcast: Calls for the reintroduction of Tax Incentives for housing                                    

In this episode, Derek Henry - Partner and Head of Tax at BDO Ireland - discusess the potential benefits of reinstating targeted tax incentives to address Ireland's housing crisis, potentially stimulating the construction of new housing, with the particular benefit for areas where development has slowed.

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BDO Global Employer Services News | February 2025

BDO’s Global Employer Services News highlights key updates for international assignees, focusing on tax and social security. Insights include Austria's Telework Act, the Government Coalition Agreement in Belgium, and Morocco's introduction of tax changes for employees and pensioners in their 2025 Budget, among other relevant developments in Canada or Singapore.

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BDO Global Employer Services News | March 2025

BDO’s Global Employer Services News highlights key updates for international assignees, focusing on tax and social security. This issue covers Belgium’s stance on French-source dividends, Botswana’s 2025/2026 budget impact, new posted worker rules in Denmark, EU-wide legislative calls on third-country nationals, and personal tax changes in France’s 2025 Finance Act.

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Irish Tax Monitor - April: VAT and Tariffs

The US administration, particularly under President Trump, has criticised EU VAT as a de facto tariff on U.S. goods. As the only OECD country without a VAT system, the U.S. has cited VAT as contributing to its trade deficit and has threatened to factor it into future tariffs, labelling it an unfair and discriminatory tax on American businesses.

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BDO Indirect Tax News | Issue 2/2025 - April 2025

This issue covers the U.S. administration’s sweeping tariff announcements and global reactions, new EU VAT rules aimed at reducing SME admin burdens, and Switzerland’s VAT risks for foreign suppliers. Also featured are compliance updates in Belgium, France, Indonesia, the Philippines, Slovenia, Spain, and more.

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BDO Global Employer Services News | April 2025

BDO’s Global Employer Services News highlights key updates affecting international assignees, with a focus on tax and social security. Among other topics, this issue features Ireland’s updated mileage and subsistence rates, Japan’s 2025 tax reform implications, and changes to the Dutch expat ruling regime. 

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