Consultative Committee of Accountancy Bodies Ireland

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Contributed to the discussion on improvements and enhancements to the research and development (R&D) tax credit regime.

Requested Revenue to design a relevant tax return for Investment Limited Partnerships (ILPs) to complete and file.

Requested Revenue to clarify the meaning of “associated entities” in the context of partnerships and the Outbound Payment Defensive Measures. We raised a point in how the definition is discussed differently in other guidance materials.

Requested Revenue to provide details on the delays in obtaining withholding tax clearances and refunds for Irish Real Estate Funds.

Requested Revenue to provide guidance on what is considered a clarification or a supplemental rule in updates to Pillar 2 OECD guidance.

Requested Revenue confirm that a securitisation vehicle will not be secondarily liable for domestic top up tax.

Requested Revenue to update guidance on the application of Minority Owned Constituent Entity provisions to orphan securitisation entities.

Requested Department of Finance to amend the legislation to expand the territorial scope of the dividend participation regime and to remove/reduce the 5-year look back rule.

Requested Revenue not to remove wording relating to day-to-day tax advice in the guidance on the mandatory disclosure regime. The removal may create unnecessary uncertainty potentially expanding the scope of the rules and the reporting requirements beyond what was originally envisaged.