Last week, Finance (No.2) Bill 2013 was presented to the Irish parliament; Deloitte has reported that one of the key changes that was published is the measure to tackle the issue of ‘stateless companies’ in order to ‘eliminate arbitrage opportunities using the tax residence rules of Ireland and its treaty partners … Where an Irish-incorporated company is not tax resident in any location because it is managed and controlled in a tax treaty country that determines tax residence according to the place of incorporation/registration, the company will be treated as tax resident in Ireland under Ireland’s place of incorporation test.’ This new rule took effect for new Irish-incorporated companies from 24 October 2013, but will take effect for existing Irish-incorporated companies from 1 January 2015.
Last week, Finance (No.2) Bill 2013 was presented to the Irish parliament; Deloitte has reported that one of the key changes that was published is the measure to tackle the issue of ‘stateless companies’ in order to ‘eliminate arbitrage opportunities using the tax residence rules of Ireland and its treaty partners … Where an Irish-incorporated company is not tax resident in any location because it is managed and controlled in a tax treaty country that determines tax residence according to the place of incorporation/registration, the company will be treated as tax resident in Ireland under Ireland’s place of incorporation test.’ This new rule took effect for new Irish-incorporated companies from 24 October 2013, but will take effect for existing Irish-incorporated companies from 1 January 2015.
