ITI Urges Irish Government To Boost Tax Treaties

by Jason Gorringe, Tax-News.com, London

01 November 2006

In its Pre-Budget Submission 2007, published earlier this month, the Irish Taxation Institute called on the government to increase the number of tax treaties in place with other countries.

Drawing attention to the success of the Republic's low corporate tax rate in attracting businesses to locate in the country, the ITI nevertheless observed that:

"If we wish to maintain our competitive position as an attractive location for foreign investment, we will need to address a number of key tax policy issues."

It continued:

"The overall tax package rather than purely the tax rate will be a critical factor for any business faced with a location or expansion decision...Our tax treaty network is a central part of the overall tax package. A comprehensive tax treaty network is critical to enabling global business to do business."

"In short, those countries with a comprehensive tax treaty network are best placed to attract inward investment and win the economic and employment benefits that come with such developments."

The ITI went on to suggest that Ireland's tax treaty network is lagging behind traditional competitors such as the UK, the Netherlands and Belgium, as well as newer EU member states, such as Malta and Hungary, which are "actively marketing their particular advantages as a location for business and currently have more treaties in place than Ireland".

"As a result, expansion and investment decisions are going against Ireland," the Institute concluded.

In order to reverse this trend, the ITI proposed four changes to the country's tax code. These were:

• That a policy be adopted to remove the preference for dealing with tax treaty jurisdictions;
• That certain benefits within the treaties be extended where the ultimate parent company is in an EU or treaty country;
• That a 'white list' of key countries be formulated through consultation with business and the tax profession; and
• That a minimum of 10-15 new treaties be ratified by Budget 2012, with an immediate focus on key jurisdictions with which Ireland does not as yet have a tax treaty, and where one is deemed to be urgently needed.

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