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The Tax Appeals Commission's 2025 annual report reveals significant trends in Irish tax dispute resolution, including a fourfold increase in appeal values and growing complexity of cases involving European law. With corporation tax disputes representing 64% of the quantum despite only 5% of appeals, and proposed legislative changes potentially shifting to public hearings, taxpayers face an evolving landscape requiring early preparation and strategic readiness.

The Irish High Court overturns the Determination of first tier Tax Appeal Commissioner to conclude that that a Delaware LLC was not "liable to tax" and therefore not "resident" within Article 4...

The winds of change that have swept through the international tax landscape in recent years show no signs of abating, and reform remains the order of the day.

In July 2023, the Irish Department of Finance published draft legislation containing new tax measures which would apply to certain payments from Irish companies.

As part of its OECD Inclusive Framework on BEPS (IF) commitments, Ireland committed to implement BEPS Action 14 (Making Dispute Resolution Mechanisms More Effective) to resolve treaty-related disputes in a timely, effective and efficient manner.

The European Union has proposed a comprehensive recast of its Directive on Administrative Cooperation (DAC), aiming to consolidate nine existing directives into a single framework while addressing longstanding concerns about reporting burdens.

Further to our update on 3 May 2017, the revised Shareholders' Rights Directive EU/2017/828 entered into force on 9 June 2017. EU Member States have until 10 June 2019 to transpose it into domestic law.

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.

Ireland is one of the world's leading locations for international operating companies.

In July 2023, the Irish Department of Finance published draft legislation containing new taxation measures which would apply to payments from Irish companies.

The EU Directive on Faster and Safer Relief of Excess Withholding Taxes (the "FASTER Directive") was approved at the May meeting of the Economic and Financial Affairs Council ("ECOFIN").

With Ireland emerging from its IMF/EU bailout and returning to the debt market, Budget 2014 was delivered on October 15, 2013.

In light of the COVID-19 crisis and the disruptions to business and the movement of people, the Irish Revenue Commissioners (the "Irish Revenue") published on 23 March 2020 a number of...

On 14 February 2019, the Luxembourg Chamber of Deputies voted to approve the OECD sponsored Multilateral Convention to Implement the Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting.

The Irish Finance Act 2012 has been enacted, giving effect to the measures contained in Finance Bill 2012.

The OECD recently published its Stage 2 MAP Peer Review Report for Ireland on the implementation of BEPS Action 14.

The Irish Revenue Commissioners ("Revenue") have recently published a new tax and duty manual containing guidelines for correlative adjustment claims under Ireland's double tax treaty network ("CA Guidance").