OECD BEPS consultation process opens

On May 27th, 2014, the Minister for Finance launched an OECD Base Erosion and Profit Shifting (“BEPS”) consultation process. Ireland has played a very active role in the OECD BEPS initiative to date. The purpose of the consultation process is to gather views on how Ireland’s tax system might need to change in response to a changing international tax landscape.

Consultation topics and questions
Views in respects of all relevant issues are welcomed, including the BEPS Action Plan (Treaty Abuse Provisions, Preferential regimes, Hybrid mismatch arrangements…), Digital Economy, Company Residence Rules for 21st Century, and Other BEPS Actions.

There are six consultation questions:

Question 1:
Which of the international tax issues identified in the BEPS Action Plan would need to be considered the highest priorities for Ireland for examination with a view to action?

Question 2:
Are there other current international tax proposals that would be of concern to Ireland?

Question 3:
In a changing international environment, what’s the best way for Ireland to ensure that its taxation provisions, for example in relation to intangible assets, are competitive?

Question 4:
Are Ireland’s company residence rules appropriate in the context of BEPS and other international tax developments?

Question 5:
What are the critical considerations in shaping Ireland’s response to current international tax developments—either in general or with respect to particular issues?

Question 6:
Are there any other priority areas or future challenges that should be considered as part of this process?

The consultation process
The consultation period will run until 22nd July 2014. Please send your comments to us by 15th July 2014 to allow sufficient time for incorporation and preparation for the final response to the Department of Finance.

How to submit your comments
Please send your comments via email to

Further information
Further details of the consultation process can be viewed in the consultation document.

Submit your comments to:

To help you with the process

To assist you with this process of how BEPS impacts your operations both locally and globally, we have developed significant dedicated resources, among which is an assessment tool which helps identifying the potential impact of the BEPS Action plans on your business. The following graph shows the results of a case study of a typical multinational.

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