Announcement exit tax for corporations transferring assets offshore

Discussion in 'Budget 2019' started by Brendan Burgess, 9 Oct 2018.

  1. Brendan Burgess

    Brendan Burgess Founder

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    Last edited: 9 Oct 2018
    Vorporation Tax – Anti Tax Avoidance Directive

    Exit Tax
    As part of Ireland’s commitment to implementing the Anti-Tax
    Avoidance Directive (ATAD), Budget 2019 introduces a new ATAD
    compliant exit tax regime from Budget night. It will tax unrealised
    capital gains where companies migrate or transfer assets offshore
    such that they leave the scope of Irish tax. The rate for the new
    ATAD compliant exit tax will be set at 12.5%. Early introduction of
    this measure will provide certainty to businesses currently located
    in Ireland and considering investing in Ireland in the futur
     
    Last edited: 9 Oct 2018
  2. Brendan Burgess

    Brendan Burgess Founder

    Posts:
    36,141
    Controlled Foreign Company (CFC) Rules
    The Finance Bill will also provide for the introduction of a Controlled
    Foreign Company (CFC) regime as required by the ATAD. CFC rules
    are an anti-abuse measure, designed to prevent the diversion of
    profits to offshore entities (the CFCs) in low- or no-tax jurisdictions.
    CFC rules are traditionally a feature of territorial tax regimes. As
    Ireland has a worldwide tax regime, CFC rules have not previously
    been a feature of the Irish corporate tax regime
     
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  3. Setanta12

    Setanta12 Frequent Poster

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    Interesting to note that Ireland was argued to be a low-tax jurisdiction in some overseas court-cases where their local CFC rules were challenged by tax-payers. (The taxpayer won in that particular instance)