#Auteur: Kevin¤ SMITH
#Qualités: Partner, Matheson (Dublin)
#Auteur: Finn¤ KELLY
#Qualités: Associate solicitor, Matheson (Dublin)
Ireland has had a domestic GAAR for many years and, as a result, did not introduce any new measures or amend its existing GAAR as a consequence of ATAD. Ireland's GAAR could be said to be broader than the minimum standard required by ATAD. In addition, Ireland's GAAR has been considered by the Irish Supreme Court in a recent case.
Introduction
1. The following table reflects how ATAD has been transposed into Irish law.
ATAD provision | Provision in Taxes Consolidation Act 1997 | Transposed |
Interest limitation (Article 4) | Not yet transposed | Expected date 1 January 2021 |
Exit taxation (Article 5) | Sections 627 629C | 1 January 2019, with effect from 10 October 2018 |
GAAR (Article 6) | Section 811C | Pre-existing |
CFC rules (Articles 7 and 8) | Sections 835I to 835Y | 1 January 2019 |
Anti-hybrid rules (Article 9 and ATAD 2) | Sections 835Z to 835AX | 1 January 2020 |
How ATAD Directiv...
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