Ireland's Retroactive Exchange Of Information Regime

The Irish Revenue Commissioners ("Revenue") recently confirmed that Ireland's spontaneous exchange of information regime (the "Regime") will apply to certain tax rulings issued as far back as 1 January 2010. Taxpayers should review confirmations and opinions received from Revenue on international tax matters since that date to determine the extent of what may be exchanged.

The Regime

The Regime is based on a combination of the framework proposed by the OECD under BEPS Action 5 (the "OECD Framework") and the EU Council Directive 2015/2376 (the "EU Rules"). In general, the Regime applies to rulings relating to transactions with a cross-border impact such as:

(i) cross-border rulings relating to preferential regimes (ie, the knowledge development box);