Cross-Border Irish Tax Matters

1. Introduction

With Ireland's 12.5% tax rate accepted by all other EU Member States and further endorsed in today's Budget, we are continuing to advise numerous multi-national companies ("MNCs") on the use of Ireland as part of their global strategy.

The continuing EU discussions about "fiscal unity" are driven by a desire by all EU leaders and finance ministers to avoid excessive EU Member States' fiscal deficits. It is not in itself a challenge against any one country's ability to either set its own tax rates or necessarily to provide a uniform EU tax code in relation to tax amortisation, deduction for finance costs, tax exemption for dividends and other income or gains. Nonetheless, the EU debate on tax is widening. On 11 November Algirdas `emeta, EU Commissioner for Taxation, launched a public consultation on non-discriminatory double taxation, whilst the Commission simultaneously launched a proposal to widen the Interest and Royalty Directive.