EU & International Developments / All

Sharon Burke reviews the status at the end of December 2015 of the adoption by Ireland of measures recommended in the final reports released on 5 October 2015 by the OECD under its Base Erosion and Profit Shifting (BEPS) Plan.

The European Commission has announced proposals to review adoption of a mandatory common corporate tax base with the ambition to move over time to a consolidated common corporate tax base. KPMG has considered the CCCTB proposals and what they might mean for Ireland and Irish based business.

For tax executives in Europe, the future of international taxation is increasingly uncertain. The global project to address tax base erosion and profit shifting (BEPS) continues to build momentum.

The reports are a significant step in the process of designing a framework for the global taxation of cross border business. They represent the conclusion of the discussion and debate phase of the BEPS Plan.

The Organisation for Economic Cooperation and Development (OECD) released on 5 October 2015 much heralded final reports under its Action

Where groups have offshore holding structures for intangible assets, they will need to consider existing pricing under such structures and perhaps consider whether their preference will be to bring the intangible assets into a jurisdiction with greater economic substance. Ireland is well placed to b

We believe that Ireland is likely to respond to BEPS measures by following a mixed approach. We expect that Ireland will adopt in the near term measures that have won widespread consensus and which enhance the transparency reputation of its tax regime.

The October 2015 report on Action 2 of the Plan contains detailed technical guidance for countries to use when designing measures for local adoption in order to deny the benefits of hybrid mismatches arising in their jurisdictions. These measures, although complex and detailed, have gained widesprea

Although this is still an early stage of review, based on our analysis of measures we expect countries to enact, we have set out below KPMG insights on the combined effect of future BEPS measures which are likely to be of interest to internationally owned businesses operating in Ireland.