Ireland — Orbitax Country Chapters

Table of Contents

ABOUT THE AUTHOR

INTRODUCTION

1. FORMS OF DOING BUSINESS

1.1. Main Forms of Doing Business with a Legal Presence

1.1.1. Main Forms of Doing Business

2. FORMATION

2.1. Main Formation Requirements

2.2. Tax Consequence of Contributions

3. CORPORATE RESIDENCE

3.1. Corporate Tax Residence

4. PERMANENT ESTABLISHMENTS

4.1. Domestic PE of a Foreign Entity

4.2. Branch Profit (Deemed) Remittance Tax

5. TAX BASE

5.1. Tax Base for Resident Entities

5.2. Treatment of Foreign Profits / Losses

5.3. Tax Consolidation / Group Treatment

5.4. Tax Base for Non-Resident Entities

5.5. Source Rules with Respect to Income Derived by Non-Residents

5.6. Qualification of Specific Income Categories for Tax Purposes

6. DETERMINATION OF TAXABLE INCOME

6.1. Main Rules Governing the Determination of Taxable Income

6.2. Main Differences between Commercial and Tax Accounting

6.3. Depreciation and Amortization

6.4. Reserves and Provisions

6.5. Deductions

6.6. Excluded and Segregated Income

8.2.1. Corporate/Profit Taxes

8.2.2. Withholding Taxes

8.3. Exit Strategies

9. FOREIGN TAX CREDITS

10. INCENTIVES AND SPECIAL REGIMES

11. BUSINESS TRANSFORMATION AND RE-ORGANIZATION

11.1. Direct and Indirect Tax Consequences of Re-Organizations

11.2. Tax Consequence of Business Emigration, Corporate Inversions and the Cessation of Business

12. VAT ON INTERNATIONAL TRANSACTIONS

12.1. VAT on the Supply of Goods by Non-Residents

12.2. VAT on the Supply of Services by Non-Residents

12.3. Refund of VAT to Non-Residents

13. BASE PROTECTION AND ANTI-AVOIDANCE MEASURES

13.1. GAAR and General Anti-Avoidance Measures

13.2. Thin-capitalization and other Restrictions to Interest Deduction

13.3. CFC and Similar Regimes

13.4. Transfer Pricing

13.4.1. Main Rules

13.4.2. Specific TP Issues

13.4.3. Documentation Requirements

13.4.4. APAs and Dispute Resolution Mechanisms

13.5. Other Anti-Avoidance Rules

14. TAX MANAGEMENT AND COMPLIANCE

14.1. Books and Records

14.2. Type of Assessment

14.3. Calendar of Important Compliance Events

14.4. Tax Audits

14.5. Interest and Penalties

14.6. Interest Compensation for Overpayment of Tax

14.7. Appeal Procedures

13.5. Other Anti-Avoidance Rules

None.

AuthorOrbitax
CountryIreland
Updated4 May 2023
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European Commission Approves Reintroduction of Bulgarian Aid Scheme to Support Investments by SMEs in High-Unemployment Areas

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ATO Publishes Quarterly General Interest Charge Rates and Shortfall Interest Charge Rates for First Quarter of 2022-23