Contributing Firms:
In this issue

Budget 2025 and increasing global tax uncertainties

The annual cycle that starts the Budget 2025 process kicked off at the National Economic Dialogue on May 27th with addresses in Dublin Castle at a conference attended by Government bodies, NGOs and industry representative and lobbying bodies who traditionally supply the Government with their ideas for the forthcoming Budget, set to be the last before the next Irish general election.


This Month's Roundtable

Budget 2025; securitisation; revamping EIIS; BEPS

In this month’s roundtable the panel looks ahead to Budget 2025, an election budget that could conceivably set the budgetary agenda for the next five years. The steps that can take to enhance Ireland’s securitisation regime, through a taxation lens, also features, as does the end of the UK ‘non-dom’ regime. With a planned review of the Employment Investment Incentive Scheme in 2024, the current state of play is analysed along with changes that could make the scheme more attractive to investors; as are the latest BEPS developments and the review of the Office of the Sheriff.


This Month's Roundtable - The Answers

Budget 2025 - ‘the election budget’

The next Budget will be an election Budget, meaning it will be the Budget that is likely to precede the next General Election, and also will be a defining opportunity for the new Cabinet ushered in by a new Taoiseach, Simon Harris to set out an election agenda for the next five years for the 3 Coalition parties. The August 2023 edition of Finance Dublin featured in its cover story your overview of the Budget Submissions for the 2023 Budget. (a) Taking these as a starting point, can you suggest ‘unfinished business’ that might be picked up from these?


A new tax deal for Securitisation

There have been proposals for the development of a new dedicated Irish Special Purpose Entity (SPE) legal framework to support securitisation and structured finance transactions (see Finance Dublin February 2024) to sit alongside the tried and tested Section 110 company option for the activity. Looking at Ireland’s regime for securitisation how could it be enhanced from a taxation perspective, especially in light of international tax reforms such as BEPS?


The taxation of the UK’s ‘Non Doms’

In the final Budget before the forthcoming UK general election the Chancellor announced the end of the taxation regime for UK resident non-domiciled individuals. Are there any likely implications for Ireland as a result of this change? What are the potential implications for other domiciles, including Ireland?


The Review of the Office of the Sheriff

The Minister for Justice has published a report on the role of Sheriffs in the State. The Department of Justice and the Office of the Revenue Commissioners established a Joint Review Group to focus on the future role of Sheriffs and to establish whether there is a more efficient and cost-effective system of debt collection. What are your observations on this?

The revamping of the EIIS scheme

There is a planned review of the Employment Investment Incentive Scheme in 2024. How does the Employment Investment Incentive Scheme work? What further changes to the scheme could make it more attractive for both investors and companies?


BEPS update

With BEPS Pillar 2 rules having come into effect at the beginning of 2024 what are the next milestones for in-scope companies subject to the rules? Are there recent developments around Pillar 2 rules that in-scope companies need to take into account?


Analysis - Special Feature

The EU Pay Transparency Directive - a cultural shift towards transparency and accountability

The days of simply relying on previous pay in decision making surrounding remuneration and keeping salary guidelines confidential will soon be a thing of the past, writes Deloitte’s Anne Kelleher. Transparency rules on how pay decisions are made, including accountability for pay equality, is to be introduced under the EU Pay Transparency Directive.


This Month's Roundtable

The Questions

Budget 2024/FA 2024: The next Budget will be an election Budget, meaning it will be the Budget that is likely to precede the next General Election, and also will be a defining opportunity for the new Cabinet ushered in by a new Taoiseach, Simon Harris to set out an election agenda for the next five years for the 3 Coalition parties. August 2023 edition of Finance Dublin featured as its cover story an overview of the Budget Submissions for the 2023 Budget. (a) Taking these as a starting point perhaps, can you suggest 'unfinished business' that might usefully be picked up from these?

Securitisation: There have been proposals for the development of a new dedicated Irish Special Purpose Entity (SPE) legal framework to support securitisation and structured finance transactions (see Finance Dublin February 2024) to sit alongside the tried and tested Section 110 company option for the activity. Looking at Ireland’s regime for securitisation how could they be enhanced from a taxation perspective, especially in light of international tax reforms such as BEPS?

UK Non Doms: In the final Budget before the next UK general election the UK Chancellor announced the end of the taxation regime for UK resident non-domiciled individuals. Are there any likely implications for Ireland as a result of this change? Please discuss any potential implications for other domiciles, including Ireland?

Review of the Office of the Sheriff: The Minister for Justice has published a report on the role of Sheriffs in the State. The Department of Justice and the Office of the Revenue Commissioners established a Joint Review Group to focus on the future role of Sheriffs and to establish whether there is a more efficient and cost-effective system of debt collection. What are your observations on this?

EIIS: There is a planned review of the Employment Investment Incentive Scheme in 2024. How does the Employment Investment Incentive Scheme work? What further changes to the scheme could make it more attractive for both investors and companies?

BEPS update: With BEPS Pillar 2 rules having come into effect at the beginning of 2024 what are the next milestones for in-scope companies subject to the rules? Are there recent developments around Pillar 2 rules that in-scope companies need to take into account?