Ireland’s Department of Finance announced a request for comments on a detailed outline of a proposed framework for Ireland’s controlled foreign company (CFC) regime, scheduled to be effective 1 January 2019. The closing date for comments is 28 September 2018
The broad outline of Ireland’s choice of CFC regime under the framework set out in the European Union (EU) Anti-Tax Avoidance Directive (ATAD) was included in Ireland’s Corporation Tax Roadmap (released 5 September 2018) and confirms that Ireland would adopt “Option B” of the two permitted ATAD approaches to a CFC rule.
Ireland’s proposed approach would seek to apply the CFC regime to undistributed profits that have been diverted, by means of non-genuine arrangements, to a “low-taxed” CFC.
The CFC regime outline suggests that Ireland’s policy makers are considering adopting a number of measures permitted under ATAD—measures that are designed either to avoid double taxation or to ease the administrative burden of the regime by:
Read a September 2018 report prepared by the KPMG member firm in Ireland
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