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Legislation & Policy Monitor (Irish Tax Review 2019 Issue 4)

Irish Tax Review Julie Burke Clare McGuinness
2019-12-09
Measures are contained in the Bill to alleviate the potential impact of a “no deal” Brexit by retaining the status quo, such as the amendment of
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UK 2018 Budget: Summary of Announcements (Irish Tax Review 2019 Issue 1)

Irish Tax Review Julie Burke Roger Campbell Mathew Scott
2019-04-01
...being an early adopter of measures to combat base erosion and profit shifting (BEPS). This raises the question of what policies can be introduced not only to attract foreign business but also to retain businesses that already have a significant footprint in the UK – especially in these turbulent Brexit times. … ...inhibit inbound investment, partly due to potential restrictions on the freedom of movement of workers, although the new immigration rules are not yet finalised. In particular, economic growth and inbound investment outside of London may be impacted by the minimum income requirements (£30K) in the proposed post-Brexit immigration system. This requirement may make it more difficult for employers to recruit employees and therefore constrain any expansion plans and inbound investment. … ...announcements should help to spur capital investment by both UK companies and overseas businesses seeking to expand operations. The reform of the intangible degrouping charge will also serve to reduce the barriers and complexities to successful M&A transactions. However, these changes have to be balanced against the general Brexit environment, which is having a much more significant impact on M&A activity. … ...reducing to 17% from 1 April 2020), significant reliefs available for R&D/qualifying patent box expenditure and an attractive dividend/withholding tax exemption – show that the UK is open for business. At the time you are reading this there may even be some clarity over what Brexit means (at least for the transitional period). If so, the impact of the tax measures introduced may have more significance.
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Legislation & Policy Monitor (Irish Tax Review 2019 Issue 2)

Irish Tax Review Julie Burke Clare McGuinness
2019-06-20
The Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Act 2019 was enacted on 17 March 2019. The Act contains the legislative measures required in the event of a no-deal Brexit and includes measures on tax, financial services, social welfare, the protection of employees and healthcare. Part 6 of the Act (ss20–66) contains the taxation measures, which cover corporation tax, income tax, VAT, capital gains tax, capital acquisitions tax and stamp duty. The Act... … The Institute had sought a VAT deferral mechanism to alleviate the cash-flow burden on businesses after Brexit in its Finance Bill-related submissions to the Minister for Finance over the last two years. The Act contains provisions for postponed accounting for VAT for all importers registered for VAT in Ireland. The measure is intended to mitigate the cash-flow impact on businesses due to the UK... … After the publication of the Withdrawal of the United Kingdom from the European Union (Consequential Provisions) Bill 2019 (“the Brexit Omnibus Bill”), the Institute made a submission to Revenue at TALC on necessary additional measures to maintain the status quo after a no-deal Brexit. Revenue said the Brexit Omnibus Bill was intended to deal with the most immediate issues in the event of a no-deal Brexit and that further measures would be included in Finance Bill 2019.
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International Tax Update (Irish Tax Review 2019 Issue 2)

Irish Tax Review Julie Burke Louise Kelly Emma Arlow
2019-06-20
UK Publishes No-Deal Brexit Guidance on Withholding Tax … On 20 March 2019 HMRC published new guidance on changes to the UK and EU withholding tax (WHT) treatment of payments of dividends, interest and royalties if the UK leaves the EU without a deal. The guidance discusses what would change (and what would stay the same) if the Parent–Subsidiary Directive (PSD) and the Interest and Royalties Directive (IRD) no longer applied....Although the UK has tax t
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