PwC statement on the Coffey report

13 September, 2017

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PwC statement on the Coffey report — PwC Ireland.

Report confirms Ireland’s corporate tax system is fit for purpose.

We welcome the publication today (12 September 2017) of the Coffey Report, which gives a clean bill of health to Ireland’s corporate tax regime.

The report is set against the backdrop of international tax policy initiatives at both an OECD and EU level and in this context it confirms that Ireland’s regime is ‘fit for purpose’ for both Irish and foreign-parented companies alike.

The report assesses Ireland against the criteria of fairness, sustainability, competitiveness and certainty. Ireland scores well on all counts.

The Report focusses on three key areas:

  1. Modernising of the Transfer Pricing regime in line with current OECD standards;
  2. Smoothing of corporate tax receipts from intellectual property;
  3. As part of introducing a CFC (Controlled Foreign Company) regime, it recommends introducing a territorial tax system (or enhanced foreign tax credit regime) to maintain Ireland’s competitiveness.

There are a number of other recommendations which are broadly in line with agreed EU/BEPS measures which Ireland will be introducing in due course.

Overall, the report recommends detailed consultation with all stakeholders, this process is to be launched on Budget Day.

Peter Reilly, Tax Policy Leader, PwC Ireland, said: “The Report is delivered in the context of recent agreements at the OECD and the EU at which Ireland was an active participant. The recommendations are in line with these agreed measures and are focussed on ensuring that companies’ people, operations and value drivers are aligned from a tax perspective.

“The transfer pricing recommendations would result in Ireland’s regime adopting principles agreed on transfer pricing during the BEPS project and may result in significant change for some companies. As a result we welcome the announced consultation process.

“The proposed changes to Ireland’s intellectual property amortisation regime will be of significance for companies who have acquired or plan to acquire IP in Ireland. The Report recommends a recalibration of Ireland’s existing IP regime to ensure some smoothing of corporate tax revenues over time.”

Joe Tynan, Head of Tax, PwC Ireland, said: “As the international tax landscape continues to change, the roadmap set forth by this report will further enhance Ireland’s competitiveness as a premier global location for investment.

“Many of the recommendations in the report will have a significant impact for companies with Irish operations, particularly in the areas of transfer pricing and intellectual property. At a time of so much change (in Ireland and internationally), it is crucial that companies take a holistic view of all of the changes that are in the pipeline to ensure they have sustainable business models for the medium to long term.”

We look forward to reviewing the Report in detail and providing feedback via the appropriate consultation channels.



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Contact us

Joe Tynan
Partner, PwC Ireland (Republic of)
Tel: +353 1 792 6399

Peter Reilly
Director, PwC Ireland (Republic of)
Tel: +353 1 792 6644

Johanna Dehaene
Corporate Communications, PwC Ireland (Republic of)
Tel: +353 1 792 6547

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