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Finance Dublin Irish Tax Monitor - July 2023

Domestic Consolidated Corporate Tax Regime

The prospect of a domestic consolidated corporate tax regime is analysed by the panel in this month’s Roundtable following a suggestion by Aircraft Leasing Ireland, in its response to the Government’s public consultation on BEPS Pillar Two, to introduce such a regime; how the private equity industry could be impacted by BEPs is also outlined in the panel, as well as the interaction between Ireland’s Qualified Domestic Top-up Tax (QDTT) and Controlled Foreign Company regimes ( notably the US’ GILTI regime); the impact of the UTPR safe harbour on Irish companies is also examined. With the Government’s review of Ireland’s funds sector in full swing the panel also examines areas of taxation that could be simplified to further enhance Ireland’s funds regime. The advantages of a territorial tax regime also feature as does the possibility of a QDTT causing double taxation on certain corporates. 

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