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Consultation on Coffey review 

The Government’s commitment to the 12.5% corporation tax rate was reaffirmed again on Budget Day, with the Minister noting that “Ireland must compete, not only on the rate but on the ability to offer certainty.”

A pubic consultation is now underway to consider the recommendations contained in Mr Seamus Coffey’s Review of the Corporate Tax Code. The consultation process, which is due to close on 30 January 2018 covers:

  • the implementation of the Anti-Tax Avoidance Directive (ATAD); 
  • the implementation of Action 8-10 of the BEPS project (i.e. aligning transfer pricing outcomes with value creation); 
  • additional considerations regarding Ireland’s domestic transfer pricing rules and the effects of moving to a territorial corporation tax base and the simplification of Schedule 24 TCA 1997.

Capital Allowances for Intangible Assets 

The recommendation in the Coffey report to limit to 80% the amount of capital allowances/interest relief that can be claimed for intangible assets has been implemented with effect from midnight 10th October 2017 for assets acquired from that date. This measure is aimed at smoothing corporation tax revenues and is a timing issue only in terms of ability to claim relief rather than a restriction.

Accelerated Capital Allowances for Energy Efficient Equipment 

The scheme of 100% accelerated capital allowances for energy efficient equipment has been retained until the end of 2020.

CGT Group Relief

The Finance Bill extends the definition of a group company for CGT group relief to include companies resident in tax treaty counties. Up to now the definition of group for this relief for inter-company asset transfers only applied to companies resident in EU or EEA states.

Return to: Budget 2018 Analysis

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