Ireland Tax News
Ireland implements European Company Statute
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Final Report on Improving the Resolution of Tax Treaty Disputes
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
Budget for 2007 - highlights
Report on Attribution of Profits to PEs released
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
German Federal Tax Court holds CFC rules not applicable in cases of administratively limited tax relief in order to comply with low taxation threshold
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
Status of Irish common contractual funds under the Ireland-US tax treaty
Treaty between Ireland and Italy – Irish CGT not covered
Finance Bill 2006
Additional protocol between Ireland and Portugal signed
On 7 December 2005, the Budget for 2006 was presented by the Minister of Finance. Unless otherwise stated, the proposals are expected to take effect from 1 January 2006. The proposals for companies include: the introduction of measures to restrict relief for interest paid in the context of certain related company transactions with effect from 7 December 2005.
In September 2005, the Revenue Commissioners announced the withdrawal, pending the receipt of legal advice on the subject, of their previous view that Irish capital gains tax is a tax
The maximum rates of withholding tax are:
As from 1 January 2006, the 2003 income tax treaty, signed on 8 October 2003, will replace the 1966 income tax treaty.
The first-time income and capital tax treaty between Iceland and Ireland , signed on 17 December 2003, entered into force on 17 December 2004. The new treaty generally applies from 1 January 2005.
The first-time income tax treaty between Greece and Ireland and the related protocol, signed on 24 November 2003, entered into force on 29 December 2004. The new treaty generally applies from 1 January 2005.
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