Contributing Firms:
As we look ahead at 2026 the panel outlines their hoped-for changes to Ireland’s tax regime in the coming year with improving the taxation of investment funds for Irish investors, and fully implementing the recommendations of Funds Sector 2030 featuring prominently. The beed for eform of Ireland’s interest regime is highlighted as is the delayed introduction of a foreign branch exemption to complement the participation exemption for foreign dividends.
While Budget 2026 delivered on a number of fronts there were topics that did not progress as hoped. With this in mind the panel outlines their wishlists of tax measures for the coming two Budgets under new Minister for Finance Simon Harris. The year in tax is reviewed with the likely fallout from the US move to exempt US multinationals from Pillar 2 rules analysed. Also featuring this month is new OECD guidance around Permanent Establishment which looks to tackle the sticky point of how cross-border ‘working from home’ arrangements impact PE. Other topics include the UK Budget and its impact on competitiveness relative to Ireland, treasury, auto enrolment and TAC determinations.
The new Minister for Finance, Simon Harris has two budgets, the 2027 and the 2028 ones, to make his mark before departing the Department to take up his scheduled appointment as rotating Taoiseach. Can you provide a list of your top priorities? (There have been a few ‘wishlist’ items left on the table in Budget 2026, as noted in the past two editions of the Irish Tax Monitor and perhaps these could rank amongst your top recommendations for Minister Harris - focussing particularly, we suggest, on Budget 2027.)
Looking back to the start of 2025 - when the prospects for example, for the OECD BEPS process were rather different than they are today, can you list and briefly comment on the most important overall events and themes that corporate tax planners will have, and will need to be aware of facing into 2026?
The OECD recently published updated guidance on the Permanent Establishment (PE) article of the Model Tax Convention, including specific guidance on cross-border working from home or other relevant place and its impact on the PE analysis. Please provide an overview of the guidance and the implications for businesses with employees working remotely from different jurisdictions.
Taking both Chancellor Reeves’ second Budget (delivered on Nov 26th) and her first last year, can you assess the cumulative impact of both on the overall tax competitiveness of Ireland relative to the UK. (Relevant topics might include moves on Non Doms last year in the UK and on inheritance tax, as well as developments this year - e.g. the introduction of a charging tax in Northern Ireland for EVs, which will not, of course, apply south of the border).
What Determinations of the Tax Appeals Commission stand out as being of particular long term significance in your opinion?
Various tax reforms to boost pensions and savings are beginning to be recommended in both Ireland and at EU level, and not least in outgoing Finance Minister Paschal Donohoe’s last speech referenced in the cover story of the November issue of Finance Dublin. Can you comment on the prospects for further desirable developments adding to the Auto Enrolment plan, which kicks in on January 1st?
Multi Currency Notional Cash Pooling”, is a treasury product that offers multinational companies tax efficiency advantages alongside others, such a zero fx costs, and is seeing strong interest from multinational companies in Ireland. Can you comment on the potentials of this and other treasury products to mitigate tax compliance processes for multinationals operating out of Ireland?
Wishlist of Tax Measures for 2026-2027: The new Minister for Finance, Simon Harris has two budgets, the 2027 and the 2028 ones, to make his mark before departing the Department to take up his scheduled appointment as rotating Taoiseach. Can you provide a list of your top priorities? (There have been a few 'wishlist' items left on the table in the 2026 Budget, as noted in the past two editions of the Irish Tax Monitor and perhaps these could rank amongst your top recommendations for Minister Harris - focussing particularly, we suggest, on the 2027 Budget.) (Finance Dublin will be featuring an exclusive interview with the Minister early in the New Year).
The UK Budget & Ireland (ROI): Taking both Chancellor Reeves' second Budget (delivered on Nov 26th) and her first last year, can you assess the cumulative impact of both on the overall tax competitiveness of Ireland relative to the UK. (Relevant topics might include moves on Non Doms last year in the UK and on inheritance tax, as well as developments this year - e.g. the introduction of a charging tax in Northern Ireland for EVs, which will not, of course, apply south of the border).
Year in Review - 2025: Looking back to the start of 2025 - when the prospects for example, for the OECD BEPS process were rather different than they are today, can you list and briefly comment on the most important overall events and themes that corporate tax planners will have, and will need to be aware of facing into 2026?
Notable Tax Determinations at the TAC in 2025: What Determinations of the Tax Appeals Commission stand out as being of particular long term significance in your opinion?
Pensions Developments and Auto Enrolment: Various tax reforms to boost pensions and savings are beginning to be recommended in both Ireland and at EU level, and not least in outgoing Finance Minister Paschal Donohoe's last speech referenced in the cover story of the November issue of Finance Dublin. Can you comment on the prospects for further desirable developments adding to the Auto Enrolment plan, which kicks in on January 1st?
Tax & Treasury: "Multi Currency Notional Cash Pooling", is a treasury product that offers multinational companies tax efficiency advantages alongside others, such a zero fx costs, and is seeing strong interest from multinational companies in Ireland. Can you comment on the potentials of this and other treasury products to mitigate tax compliance processes for multinationals operating out of Ireland?