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ARTICLE · 29 OCTOBER 2013

Irish Law Changes For 'Stateless' Companies – Preparing For The Future

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The Irish Minister for Finance today, Thursday, 24 October 2013, published the Finance Bill (No. 2) 2013 (the "Finance Bill").

IrelandTax
Andrew Quinn
Andrew Quinn
William Fogarty
William Fogarty
Edward Miller
Edward Miller
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The Irish Minister for Finance today, Thursday, 24 October 2013, published the Finance Bill (No. 2) 2013 (the "Finance Bill"). 

As announced by the Minister in his Budget statement last week, the Finance Bill contains "a change to Irish company residence rules aimed at eliminating mismatches – that can exist between tax treaty partners in certain circumstances – being used to allow companies to be 'stateless' in terms of their place of tax residence."

Irish incorporated companies which are not resident in Ireland are used in significant international corporate structures, and the concept of a stateless Irish company has recently drawn considerable public and media comment.  This new measure can be seen as part of Ireland's proactive approach in ensuring the Irish corporation tax system is robust internationally, such as its recent work in advancing the OECD's Base Erosion and Profit Shifting (BEPS) project and countering cross border 'double no tax' arrangements. 

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