Ireland MOF Seeks Comments on Phase One of Interest Tax Reform Regime

The Irish Department of Finance Nov. 21 opened a consultation on Phase One of the interest tax reform regime. The consultation includes proposals to: 1) introduce new corporation tax interest deduction rules, including a profit motive test and consideration of the new test with existing provisions; 2) address gaps in transfer pricing international guardrails by extending transfer pricing rules to medium-sized enterprises employing fewer than 250 individuals and annual turnover not exceeding 50 million euros (US$57.6 million), and annual balance sheet totals not exceeding 43 million euros (US$49.5 million); 3) align the tax treatment of trading and passive interest income ...