TEI comments on Irish BEPS consultation.

PositionTax Executives Institute, base erosion and profit shifting

On July 21, 2014, TEI submitted comments to the government of Ireland regarding its public consultation document OECD Base Erosion and Profit Shifting Project in an Irish Context. TEI's comments focused on the need for certainty should the Irish government change its corporate tax regime in conjunction with OECD's BEPS project. In particular, TEI recommended that the Irish government provide taxpayers with a significant transition period if any changes are made to the Irish corporate residency rules and implement a formal ruling procedure to confirm the tax consequences of any restructurings taxpayers undertake to conform to a new Irish tax regime. TEI's comments were prepared under the aegis of TEI's European Direct Tax Committee, whose Chair is Nick Hasenoehrl of Herbalife. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

On 27 May 2014, the Ireland Department of Finance (hereinafter, the Department) announced a public consultation regarding the Organisation for Economic Co-Operation and Development's Base Erosion and Profit Shifting (BEPS) project. The public announcement stated that "the Minister for Finance ... wishes to consider options for Ireland's tax system to respond to a changing international tax environment" in the context of the BEPS project and in light of a desire to maintain the competitiveness of Ireland's overall corporate tax regime. In that regard, the Department released a consultation document, OECD Base Erosion and Profit Shifting Project in an Irish Context (hereinafter, the Consultation Document), and invited interested parties to submit their views. On behalf of Tax Executives Institute, Inc., I am pleased to respond to the Department's invitation.

TEI Background In General

Tax Executives Institute, Inc. (hereinafter, TEI or the Institute) was founded in 1944 and is the preeminent association of in-house tax professionals worldwide. Our approximately 7,000 members represent nearly 3,000 of the leading corporations in Europe, the United States, Canada and Asia. TEI's EMEA Chapter, which includes members resident in Europe, the Middle East, and Africa, was chartered in 1999 and has grown to include over 225 members. TEI represents a cross-section of the business community, and is dedicated to developing and effectively implementing sound tax policy, to promoting the uniform and equitable enforcement of the tax laws, and to reducing the cost and burden of administration and...

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