Exit tax

As part of Ireland’s commitment to implementing the Anti-Avoidance Tax Directive, Budget 2019 introduced an exit tax regime which takes effect from Budget night.

The tax will arise where companies migrate or transfer assets offshore and are no longer within the scope of Irish tax. An exit tax at 12.5% will apply to all unrealised gains.

Controlled foreign company (CFC) rules

Budget 2018 announced that the government would introduce controlled foreign company (CFC) rules, to prevent the diversion of profits to offshore entities in low-tax or non-tax jurisdictions. To date, CFC rules have not been part of the Irish tax regime. Budget 2019 confirms that CFC rules will apply for accounting periods commencing on or after 1 January 2019.

Transfer pricing

The Minister has also committed to carrying out a review of the existing transfer pricing legislation to ensure that it is in line with international best practice.