BEPS Ireland Profile

July 2016

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1) Has Ireland implemented any BEPS recommendations? If so, which Action Items? 
Yes, country-by-country reporting is applicable with effect from January 1, 2016.
 
2) What is Ireland’s expected timeline for implementing country-by-country reporting? 
Country-by-country reporting is applicable with effect from January 1, 2016.
 
3) If Ireland has already implemented CbC, what has been the reaction from taxpayers? 
There has been no negative reaction so far.  In a number of cases, taxpayers have publicly welcomed the greater transparency brought about by country-by-country reporting.
 
4) What measures are multinationals in Ireland taking to prepare for country-by-country reporting?  
Country-by-country reporting is only applicable to large groups headquartered in Ireland.  Compared to larger jurisdictions, the pool of impacted multinationals in Ireland is relatively small.
 
5) If Ireland has already implemented CbC, what challenges are taxpayers facing or anticipated to face? 
From industry discussion, we understand that the primary challenge is accessing and collating data globally. In Ireland, there are some questions around the repercussions of the U.S. not implementing country-by-country reporting in 2016.  Furthermore, if the U.S. elects an Irish subsidiary as a deemed parent for one year, there are questions surrounding whether the Irish subsidiary can then access information globally, or it can require other subsidiaries to provide it with information.
 
6) Are Ireland’s taxing authorities taking any measures to prepare for any changes brought about by BEPS (e.g., changes in staffing, increases in budgets)? 
The Irish tax authorities are increasing transfer pricing resources and hiring more employees from industry. They are also hiring tech/IT personnel to increase data analytics resources.
 
7) How will country-by-country reporting affect how you provide services to your clients? 
Since BDO Ireland does not have its own transfer pricing resources, country-by-country reporting will increase the scope for BDO Ireland to seek a firm within the BDO network with a larger transfer pricing practice.