Authors: Louise Kelly, tax partner and Andrew O’Reilly, R&D Tax Credit manager, Deloitte
In this article, we will discuss the tax changes announced by Budget 2015, with a particular focus on the Research and Development Tax Credit regime.
In drafting Budget 2015, the Department of Finance had to take account of a changing international tax landscape. During 2014, the focus on tax planning techniques used by multinationals has continued to intensify. Meanwhile, the OECD’s Base Erosion and Profit Shifting (BEPS) project reached the half-way mark in September 2014, when the first phase of draft reports were published.
Against that backdrop, the Irish Government developed its international tax strategy for Ireland and the Road Map for Ireland’s Tax Competitiveness was published as part of Budget 2015. The Road Map re-emphasised the importance of the ‘three Rs’:
• The Corporate Tax Rate of 12.5% is certain and will not be changed;
• Tax Regime – there have been some positive changes in the areas of IP regime, the Special Assignee Relief Programme (SARP) and the R&D Tax Credit Regime;
• Reputation – changes to the corporate tax residence rules affecting the infamous ‘Double Irish’ structure.