EU & International Developments / All

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.

Readers will be aware of the increased focus on transparency in relation to the tax affairs of groups which operate internationally (MNCs).

The European Commission has released draft legislation regarding automatic exchange of information on cross-border tax rulings as part of a package of measures to combat tax avoidance and harmful tax competition.

The UK government published and is set to put into legislation a new tax entitled the ‘Diverted Profits Tax’.

Country by Country (“CbyC”) Reporting has the ability to significantly raise the tax profile of companies impacted.

On 30 June 2014, the Irish Revenue Commissioners published the Final Irish Regulations on FATCA.

Increased tax transparency is imminent and companies should conduct a BEPS Health Check.

On 19 December 2014, the OECD released its final 2014 document under its Base Erosion and Profit Shifting (“BEPS”) Plan.