The changing international tax landscape: implications for Ireland

Even a year ago, it was far from certain that international taxation consensus could be reached. Now, businesses must monitor how proposal implementation could impact them

‘A key question remains as to what extent proposed reforms to the US tax regime can be enacted by US Congress and would be sufficiently comparable to the agreement reached under BEPS 2.0. In particular, whether the US will be able to implement Pillar One and how its GILTI regime may coexist with the Pillar Two proposals are fundamental issues’. Picture: Getty

Writing this time last year, we posed the question: “Can consensus be reached by over 130 jurisdictions to fundamentally change the international tax environment?” While there remain some hurdles to overcome, the answer is looking increasingly to be yes.

Within the tax sphere, the Organisation for Economic Co-operation and Development (OECD) has for several years focused on base erosion and profit shifting (BEPS)-related initiatives. While initially focusing on the digital economy, in recent times, the ...