Ireland - Changes to residency rules to comply with BEPS 

October 25:  In Ireland's budget for 2014 (presented last week), the Minister of Finance announced that the Finance Bill would include a change to the company residence rules that would take aim at eliminating mismatches that may exist between tax treaty partners and that are used to allow companies to be "stateless" in terms of their place of tax residence.

Read TaxNewsFlash-Europe: Tax proposals in 2014 budget


With this proposal, Ireland joins other European countries in proposing legislation that apparently would be intended to comply with the OECD's intention to limit base erosion via interest deductions, as detailed in the OECD’s BEPS* action plan (July 2013).


*Base erosion and profit shifting (BEPS)




©2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

Share this

Share this