In April 2024, the Department of Finance published a Strawman
Proposal setting out some of the key potential design features of
the new Irish participation exemption for foreign dividends, that
will be introduced from 1 January 2025.
In its submission, Arthur Cox LLP noted that many of its
comments from the previous public consultation were taken into
consideration, however not all and while the 100% exemption is
welcome, it must be part of a regime that is otherwise as broad and
easy to administer as possible.
Ireland is an open economy that relies heavily on foreign direct
investment and capital importation, it is imperative that the Irish
tax regime remains competitive for maintaining and attracting
investment. Ireland has ceded much of its tax competitiveness in
recent years, both with a mitigation of the rate differential, and
with the increasingly complex and outdated nature of the tax rules.
In a post Pillar Two environment in-scope groups are
