Public Consultation on the introduction of a participation exemption(s) to the Irish corporation tax system


AmCham welcomes the firm commitment by the Minister to introduce a participation exemption for both dividends and branch profits. As noted by the Minister, Ireland is an international outlier with regards to the taxation of foreign dividends, and as such the introduction of a participation exemption is overdue. It is essential that the regime is best in class, and it should not be seen as a revenue raiser for Ireland.

As the Irish and UK tax codes have broad similarities, AmCham recommends that Ireland should adopt a regime comparable to that of the UK, which was introduced in 2009. In addition, given the complexities of the Irish tax regime, AmCham recommends that the existing mechanism for the taxation of foreign sourced dividends and branch profits is retained on an electable basis, to ensure there are no unintended consequences with the introduction of a territorial system of taxation.

You can read the full submission here