Chartered Accountants Ireland under the auspices of the CCAB-I responded to the Department of Finance’s public consultation on Ireland’s tax treaty policy. The updated Corporation Tax Roadmap 2021, published earlier this year, committed to review Ireland’s tax treaty policy, taking account of international developments, and publish a tax treaty policy statement by the end of 2021.

The consultation sought views on the economic considerations for Irish tax treaty policy and the role of treaty policy in supporting developing economies. The CCAB-I made the following recommendations and observations:

• Ireland’s tax treaty policy needs to consider the implications of remote working abroad with reference to articles on employments and permanent establishment, and their appropriateness for extensive remote working abroad.
• A broadening of the Irish tax treaty network may facilitate operations currently located in the United Kingdom seeking to maintain a presence in the European Union.
• Ireland’s tax treaty policy should look to better serve the aircraft leasing and financial services sector by focusing on supporting trade with Asian, African, and South American countries.
• Ireland’s tax treaty priorities in the context of international tax reform should seek to ensure dispute resolution mechanisms are supported, enhanced, and reformed where appropriate.
• Ireland should seek to renegotiate its double tax treaty with Japan, with a view to achieving terms like other European nations.
• Actions and supports outside of treaty policies are a more effective means of assisting developing countries.
• Ireland can support developing countries by participating in initiatives like Tax Inspectors Without Boarders.
• The practice of negotiating with developing countries should continue to be based on the provisions of both the UN and OECD model conventions.

You can read the CCAB-I’s Irish tax treaty policy submission in the Source Material section of this edition.