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Articles by Robert Dever
Ireland Enhances Tax System to Boost Multinational Investment Original
The Irish government’s draft Finance Bill 2025 aims to underscore Ireland’s attractiveness as a place for foreign direct investment, and to enhance aspects of the Irish tax system that can offer attractive benefits for multinationals doing business in Ireland. The bill follows other tax measures in Budget 2026, with the majority of the changes to take effect on Jan. 1.
Buyers and sellers must be aware of Irish ‘earn-out’ tax implications
Irish tax rules around earn-outs can give rise to some unexpected and sometimes harsh results, according to legal experts Robert Dever and Gerry Beausang of Pinsent Masons, writing in the Irish Tax Review. An earn-out is a contractual mechanism used in M&A deals where part of the purchase price is contingent upon the future performance of the business being sold.
Amundi EFT relocation highlights attractiveness of Ireland as fund hub
Robert Dever and Conor Durkin of Pinsent Masons were commenting following the strategic move by Amundi, made in a bid to optimise tax efficiency. Amundi has moved the fund to Ireland in order to benefit from the more favourable double taxation treaty between Ireland and the US, according to a company spokesperson.
Trump’s executive orders focus on energy, AI, tax, trade and climate
Global climate and tax policy are among the issues addressed in the executive orders, along with the US approach to trade, AI regulation and energy generation. Public policy expert Mark Ferguson of Pinsent Masons said the measures announced are relevant to the commercial strategies of businesses across sectors, based all around the world. “We’re at the beginning of what will be a very different Trump administration from the first one,” Ferguson said.
Employment status code updated in Ireland
The code of practice on determining employment status was updated by Irish authorities to account for a seminal ruling by the Supreme Court in Ireland last year in which the court found that Domino’s Pizza’s delivery drivers were in fact employees and not independent contractors. In its decision, the Supreme Court set out a five-step framework for determining a worker’s employment status.
EU revamps VAT system for the digital age
The new rules are set out in the VAT in the Digital Age package (ViDA), which aims to modernise the EU’s VAT system and support digitalisation of EU member states. The package brings changes in three main different aspects of VAT practices. It will make VAT reporting obligations for cross-border transactions fully digital by 2030.
Ireland’s 2025 budget offers support to start-ups and multinational businesses
Ireland’s Minister for Finance, Jack Chambers T.D., delivered his first budget speech and the last of the current government on 1 October. He said that the 2025 Budget was designed to “plan, transform and deliver for the future, with progressivity, fairness and catalysing real opportunity for the future at its core”.
Changes to Ireland’s ‘standard fund threshold’ tax regime welcomed
The changes to the SFT – which sets a lifetime maximum for tax relieved pension contributions across all pension products and schemes for both the public and private sector - are part of the government’s multi-year plan to implement the recommendations outlined in an independent review (57-page / 709KB PDF) of the SFT regime recently conducted by Dr. Donal de Buitléir.
Ireland’s Upcoming Budget Offers Chance to Move Past Apple Case Original
The European Court of Justice’s decision to make Apple Inc. pay Ireland 13 billion euros ($14.5 billion) in back taxes has raised questions about Ireland’s position as a hub for foreign direct investment. The decision undermines the government’s long-standing position that Ireland doesn’t give preferential tax treatment to any taxpayers, companies or otherwise, and will serve as fodder to those who seek to portray Ireland as a tax haven.
EU state aid enforcement could change after Apple ruling
Dr Totis Kotsonis of Pinsent Masons, who specialises in subsidy controls and state aid law, was commenting after the Court of Justice of the EU (CJEU) effectively reinstated a 2016 decision of the European Commission which ordered the Irish government to recoup up to €13 billion plus interest in unpaid taxes from US technology giant Apple. The Commission had concluded that Apple had received illegal tax benefits from the Irish government between 2003 and 2014 in breach of EU state aid rules.
Ireland refines proposed foreign dividend tax exemption approach
The proposed concession, which forms part of an ongoing consultation, was confirmed in a second feedback statement (20-page / 1.99MB PDF) on the development of the so-called ‘participation exemption’ from Irish corporate tax for foreign dividends, which is due to take effect in January 2025. The department is not, however, amenable to extending the geographical scope of the exemption, despite calls to do in response to its first feedback statement on the new regime.
What the ‘FASTER’ tax reforms could mean for EU investors
EU law makers hope the proposed directive on faster and safer relief of excess withholding taxes (FASTER) directive will make it easier for cross-border investors to claim relief from dividends and interests paid to them – and in doing so, avoid the potential for double taxation on those funds.
ECOFIN fails to reach agreement on ViDA VAT reporting package
This means that the first implementation of the package, once agreed, is not expected to occur until 2027 at the earliest. The ViDA package, first proposed by the European Commission in December 2022, aims to modernise reporting obligations for VAT purposes by standardising the information that needs to be submitted by businesses on their transaction and by imposing the use of e-invoicing for cross-border transactions. This is aimed, amongst other things, at combatting tax fraud.
EU’s FASTER Directive Aims to Speed Up Withholding Tax Reclaim
The EU’s proposed directive on the faster and safer relief of excess withholding taxes—known as FASTER—is a key step in helping to boost cross-border investment, fight tax fraud, and improve the functioning of capital markets within the EU. The Economic and Financial Affairs Council of the EU, ECOFIN, reached agreement May 14 on the proposed directive, and it’s expected to be formally adopted by the EU Council in early 2025.
OECD publishes additional guidance on global minimum tax
Part of the OECD/G20 Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the additional guidance focuses on the Global Anti-Base Erosion Model (GloBE) rules – a key component of Pillar Two – which intend to ensure that large MNEs pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.
EU multinationals must prepare to meet new public disclosure obligations
Also known as Directive 2021/2101/EU, the CbC Directive came into effect in December 2021, requiring EU member states to alter their domestic laws in accordance with the Directive by June 2023. At the latest, the rules will apply to in-scope entities from the start of the first financial year commencing on or after 22 June 2024.
Upper Tribunal provides clarity on interpretation of double tax treaty provisions
The dispute centred on the interpretation of Article 12 of the UK-Ireland double tax convention, particularly whether the assignment of a debt claim on the facts of the case had the ‘main purpose’ of taking advantage of the convention such that treaty relief should be denied. The case (26 pages / 549 KB) concerned an assignment of a debt claim from SAAD Investments Company Limited, a company based in the Cayman Islands to Burlington Loan Management DAC’s (BLM) which was based in Ireland.
Irish employers should review worker taxation classifications
The guidelines follow on from a landmark Supreme Court decision last October and includes commentary from Irish Revenue on the aspects of the decision-making framework outlined in that decision. The decision-marking framework set out by the Supreme Court consist of five questions that should be used to resolve the issue of whether a contract is one of service (employee) or one for service (self-employed).
EU Council agrees on new rules for withholding tax procedures
The proposed Faster and Safer Relief of Excess Withholding Taxes (FASTER) directive (77-page PDF/605KB) aims to help boost cross-border investment, improve the functioning of capital markets within the union, and fight tax fraud. The proposal for the FASTER directive was initially submitted by the European Commission in June 2023.
Foreign dividends reform ‘a boost Ireland’s holding company credentials’
Robert Dever of Pinsent Masons was commenting after the Irish government published its first feedback statement on the issue, including potential features of a new tax exemption it plans to introduce in respect of dividends paid by certain foreign subsidiaries to Irish entities as well as certain foreign companies with an Irish branch or agency.
Irish tax treatment of some intra-group payments to change from 1 April
Dublin-based tax expert Robert Dever of Pinsent Masons said businesses may be able to restructure their arrangements to mitigate the change, which will come in the form of withholding tax obligations and reporting requirements. Dever was commenting before reforms to the so-called outbound payments regime in Ireland begin to apply from the beginning of April.
OECD approach to ‘Amount B’ a milestone but global tax challenges remain
Transfer pricing refers to the necessary charges made between different parts of a multinational business for goods, services or intangible assets, including intellectual property. Tax rules provide that transactions between connected parties should be taxed as if they were on arm's length terms. The OECD guidelines have been updated after publication of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting’s final report on Amount B.
OECD Amount B Is a Milestone, but Shows More Needs to Be Done
The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting’s final report on Amount B represents the culmination of a great deal of effort since 2021, as well as active engagement and input by interested stakeholders. But a lot more work is necessary for Amount B to be the game-changer that many expect it could be, especially for low-capacity jurisdictions.
Pillar Two implementation feedback statement
Ireland Tax planning and consultancy - Briefings In October 2021, Ireland along with 130 other countries signed a historic agreement to reform the international tax framework. Building on the original Base Erosion and Profit Shifting (“BEPS”) project, the agreement contains a Two Pillar solution to address the tax challenges arising from digitalisation and globalisation.
A look at the European Chips Act
Ireland Tax planning and consultancy - Briefings Aims of the Chips Act On 15 September 2021, European Commission President Ursula von der Leyen announced an EU Chips Act, pointing out the necessity to link together Europe’s world-class research capacities and to coordinate European Union (“”) and national investment along the value chain.
Have you discharged your Local Property Tax?
Ireland Real estate Tax planning and consultancy Introduction to Local Property Tax Last week, Irish Revenue issued 150,000 letters to property owners who have not yet discharged, or made any arrangement to discharge, their Local Property Tax (LPT) liability. LPT was introduced 10 years ago replacing the household charge. Despite LPT being in place for a decade, changes to the 2013 regime were only made in 2021.
Share based remuneration in Ireland - key considerations and recent developments
Share based remuneration in Ireland – the key considerations and recent developments you need to know from an employment, corporate and commercial, and tax perspective.
index - Eversheds Sutherland
Ireland Tax planning and consultancy - Briefings Energy crisis – business resilience Introduction to extensions to the VAT Rate for Hospitability and the Temporary Business Energy Support Scheme (TBESS) On 21 February 2023, The Irish Government announced a new cost-of-living Package (the “Package”) which will see updates to existing temporary business supports. The publication announcing these measures can be found here.
index - Eversheds Sutherland
Ireland Real estate Real estate sector Background On 1 April 2023, local authorities must inform landowners whether their application for the exclusion of lands from the Residential Zoned Land Tax (RZLT) has been successful. RZLT was introduced by the Finance Act 2021 to “encourage the timely activation of zoned and serviced residential development land for housing”1. RZLT will ultimately replace the current vacant site levy. However, the vacant site levy will not disappear overnight.
Coronavirus - Covid Restrictions Support Scheme - Coronavirus (COVID-19) - Ireland
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Coronavirus - Updated summary of Covid-19 tax measures and Irish Revenue guidance - Ireland | Lexology
A number of measures have been introduced in Ireland in recent weeks in light of the impact of the Covid-19 pandemic. Irish Revenue has also published a number of welcome guidelines and confirmations in an attempt to mitigate any detrimental effects caused during this period of uncertainty. Set out below is a high-level overview of the relevant measures and guidance announced to date.
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