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Finance Dublin Irish Tax Monitor - April 2023

In this issue of the Finance Dublin Irish Tax Monitor the Roundtable panel analyse the ‘structural’ advantages that Irish-domiciled ETFs have in comparison to other jurisdictions, owed, in part, to its strong tax treaty network. However, all is not rosy in the ETF space, notably for Irish investors, with the ‘deemed disposal’ rule and elevated tax rate on returns in comparison to equities both highlighted. Recent BEPS guidance for insurance companies is also analysed, and welcomed, with the added clarity set to avoid any unintended consequences for that sector. The key short-term challenges facing tax managers are also analysed as are recent changes around corporation tax rules guidance and how the EU’s incoming DEBRA rule could change the debt/equity financing mix for M&A activity.

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