State plans to exempt foreign dividends from tax in ‘exchequer neutral’ move

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Ireland is ‘significant outlier’ on the taxation of foreign dividends. Department of Finance said

The move acts upon the recommendation in a government-commissioned report, written in 2017 by economist Seamus Coffey, that there should be a tax exemption on foreign dividends as well as profits of overseas branches of Irish companies. Foreign direct investment companies in Ireland have long complained about the administrative burden attached to existing “tax and credit” system that has applied in the State to overseas dividends, according to officials.

The Government is also considering introducing an exemption on profits of overseas branches of Irish companies, but this is not at as advanced a stage as the dividends plan because of complexities involved. Mr McGrath told reporters that his officials are at the drafting stage of the Finance Bill 2023, which will be published next month and pave the way for the introduction of the effective new 15 per cent rate next year. This will be levied by way of a top-up tax rate that will added to the prevailing Irish 12.5 per cent headline corporate tax rate.

“It is going to be a very complex piece of legislative work,” he said. The planned tax exemption on foreign taxes are on track to be contained in a Finance Bill to be published late next year, following the unveiling of Budget 2025. Meanwhile, Mr McGrath said that “Ireland remains deeply sceptical” about the European Commission’s recent proposal to harmonise corporate tax rules across the EU. It replaces the Commission’s previous common consolidated corporate tax base proposals, which had been withdrawn due to lack of support by many member states.

 

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