The Anti-Tax Avoidance Directive In Ireland

Ireland's Budget 2027, announced on 6 October 2026, introduces a €1.3 billion personal income tax package and projects a €9.5 billion surplus while implementing significant changes to capital gains tax...

Ireland's Budget 2027 introduces a lower exit tax rate for fund investors, clearer rules for Irish ETFs, and a new Retail Investment Account, while leaving the controversial eight-year deemed disposal rule unchanged. The package also includes Pillar Two updates, interest relief reforms, and a capital gains tax reduction, offering targeted refinements for the financial services sector rather than the fundamental reform many had anticipated.

Ireland's Budget 2027 introduces significant tax reforms aimed at boosting competitiveness and encouraging investment, including reductions in capital gains tax, simplified interest relief provisions, and a new Personal Investment Account with favorable tax treatment. The budget package totals €8.5 billion with measures focused on rewarding work, promoting entrepreneurship, and addressing housing supply challenges.

The European Union has enacted its most sweeping customs reform since 1968, fundamentally reshaping how businesses import and export goods across EU borders. The new Union Customs Code introduces stricter compliance requirements, shifts liability to importers and exporters, and establishes a centralized EU Customs Data Hub that will eventually become mandatory for all economic operators.

Most often, businesses gravitate towards the LTD model due to its familiarity and simplicity. However, DACs and Irish Collective Asset Management Vehicles...

The European Commission has proposed consolidating nine separate Directives on Administrative Cooperation into a single recast directive, aiming to simplify the EU's tax information exchange framework while maintaining transparency. However, the proposal faces significant challenges including the incorporation of previously rejected "Unshell" provisions, the requirement for unanimous approval from all 27 Member States, and questions about whether the consolidation will deliver meaningful simplification for

The Irish Budget for 2027 (“Budget 2027”) was announced by Minister Simon Harris on 6 October 2026. Budget 2027 contains a number of measures intended to support Ireland’s status as a leading financial and investment jurisdiction in Europe. International investors will welcome the introduction of reforms for the taxation of Irish corporates, the introduction of new rules to accommodate the Pillar Two side-by-side agreement with the US and the extensions to Irish tax provisions for tax credits.

Ireland's Finance (No. 2) Bill 2026 introduces significant tax reforms including a capital gains tax reduction from 33% to 31%, enhanced R&D tax credits with increased subcontracting limits, and the launch of a new Individual Investment Account allowing €12,000 annual tax-efficient investments. The legislation also implements Pillar Two safe harbours, simplifies interest taxation rules, and establishes a new Derelict Property Tax to encourage property regeneration.

Ireland's Budget 2027 shifts focus from major tax reforms to infrastructure delivery and development acceleration. With €20.3 billion allocated to capital expenditure and targeted measures for housing, energy, and transport, the budget emphasizes removing bottlenecks and improving efficiency. Notable changes include reduced investment undertaking tax rates, a new derelict property tax, and modifications to capital gains tax treatment for development land.

Ireland has introduced Section 1009A of the Taxes Consolidation Act 1997, marking the first time Irish legislation directly addresses the tax transparency of foreign entities. This groundbreaking provision has significant implications for cross-border investment structures involving Irish funds, particularly those utilizing Delaware limited partnerships, U.K. LLPs, and U.S. LLCs, with downstream consequences for Pillar 2 and anti-hybrid mismatch rules.