Ireland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS
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1 17 July 2017 Global Tax Alert Ireland signs Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS EY Global Tax Alert Library Access both online and pdf versions of all EY Global Tax Alerts. Copy into your web browser: Executive summary Along with 67 other countries, Ireland became a signatory to the Organisation for Economic Co-operation and Development s (OECD s) Multilateral Convention to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (the MLI) at the 7 June 2017 signing ceremony held in Paris. 1 In advance of signing the MLI, the Irish Department of Finance published an Irish position paper 2 on the various Articles of the MLI. As expected, Ireland adopted the majority of the MLI provisions. This included opting for the principal purpose test (PPT) to prevent tax treaty abuse as well as mandatory binding arbitration for tax dispute resolution. The reservations Ireland made on certain items should also be noted - particularly Ireland s reluctance to adopt certain permanent establishment (PE) provisions under the MLI. It is worth noting that the individual reservations do need to be considered on a per-article basis. An Irish reservation or position may be neutralized by the counter-party s position and vice-versa.
2 2 Global Tax Alert Detailed discussion The Irish Department of Finance has consistently stated it fully supports the OECD Base Erosion and Profit Shifting (BEPS) initiatives and specifically the MLI. In conjunction with the MLI signing ceremony, the Minister for Finance Michael Noonan commented: This Convention represents a very important step in the implementation of the OECD recommendations on global tax reform and tackling tax avoidance. and This Convention will ensure that Ireland s extensive network of tax treaties will continue to facilitate trade and investment and provide certainty to taxpayers. Covered tax agreements Ireland included 71 of its 72 double tax treaties currently in effect as covered tax agreements (CTAs) under the MLI. A list of treaties included by Ireland on its list of CTAs is contained in Appendix 1. The exception was Ireland s treaty with the Netherlands, which is under bilateral renegotiation between the parties. In addition, it should be noted that: The US has not signed the MLI and is not expected to sign in the near future. Switzerland has to date chosen not to include its treaty with Ireland as a covered tax agreement. 3 Ireland positions on MLI articles Hybrid mismatches Ireland has adopted Article 3 of the MLI, which deals with entities which are transparent. Article 3 provides that where an entity is deemed transparent in either Ireland or the Contracting Jurisdiction, the income earned by that entity shall be treated as income of a resident of that Contracting Jurisdiction. This is designed for the purposes of ensuring a consistent tax treatment where countries have different rules to determine whether an entity is transparent or opaque. This will be significant in an Irish context given Ireland has no anti hybrid rules apart from some specific rules associated with securitization vehicles (s.110 companies) in Ireland. Ireland has also chosen to adopt Article 4 in determining tax residence for dual resident entities. The Article provides for a more flexible tie-breaker clause, where the State of residence is determined by the competent authorities of the Contracting Jurisdictions. This represents a significant departure from the current Irish position. Domestic corporate tax residency in Ireland is based on incorporation and central management and control. In the majority of Ireland s CTAs, the residency tie-breaker clause is based on place of effective management principles. Ireland chose to reserve on Article 5 as this article deals with the exemption method of eliminating double taxation. As Ireland operates a credit mechanism under domestic law rather than an exemption system the provision is inapplicable for Ireland. Treaty abuse In the context of tax treaty abuse, Ireland did not express any reservations on Article 6 which amends the preamble in CTAs to confirm that the intention of treaties is to prevent double taxation while not enabling double non-taxation. Ireland also decided to add optional wording to the preamble of its CTAs, referring to the desire to develop economic relationships and to enhance cooperation in tax matters. Moreover, Ireland has adopted the PPT provided for in Article 7 of the MLI. Article 7 represents a BEPS minimum standard which in the context of the MLI, can be met through adoption of a PPT or through a PPT and simplified limitation of benefits (LOB) clause. This will introduce a general anti-avoidance clause into any CTA where the Contracting Jurisdiction also chooses the PPT option. This contrasts with Ireland s tax treaty with the United States (US), which contains LOB provisions. As mentioned above, the US has not signed the MLI and Ireland s treaty with the US is currently under bilateral renegotiation, outside of the MLI process. Ireland also intends to adopt an anti-avoidance rule in Article 8 providing a minimum holding period to be met before certain reduced rates on dividends are available. The dividend payments affected are those between entities resident in Ireland and other MLI Contracting Jurisdictions. It is important to consider the domestic withholding tax position in Ireland on outbound payments before assessing relief/exemptions under the respective CTAs. Ireland does not impose withholding tax on swaps, manufactured dividends or royalties (other than patent royalties). In addition, there are domestic exemptions from withholding tax available on dividend and interest payments to residents of a treaty partner country. Consequently, the relevant CTA is generally not relied upon to reduce/eliminate withholding
3 Global Tax Alert 3 on such outbound payments from Ireland. The position taken by Ireland on the MLI in relation to the PPT and minimum holding period on dividends could be more relevant in the context of structures which rely on the CTA to mitigate foreign withholding tax exposures on payments to Ireland. Ireland has also committed to implementing the Article 9 anti-avoidance provisions designed to prevent companies from avoiding capital gains tax when disposing of interests or shares that derive their value from immovable property. Furthermore, Ireland has reserved the right for Articles 10 and 11 (PE in third jurisdictions and a clause to preserve the rights to tax its own residents) not to apply to its CTAs. PE Ireland exercised its reservation on Article 12 of the MLI, which is primarily focused on tackling the artificial avoidance of PE status in the context of commissionaire and similar arrangements. The Irish Department of Finance stated that this reservation is due to the continuing significant uncertainty as to how the test would be applied in practice. Article 13 addresses the artificial avoidance of PE status through the specific activity exemptions, which are described in most tax treaties. Under this Article, signees were given two options in relation to how exemptions from PE status were to be interpreted. Ireland s preference is to apply option B which would preserve the exceptions for activities described in existing tax treaties and to ensure that those exceptions will apply irrespective of whether the activity is of a preparatory or auxiliary character. 4 This is consistent with Ireland s historic position in relation to PE issues. Ireland also intends to adopt the anti-fragmentation rule in Article 13 which is designed to prevent corporate groups from dividing a cohesive operating business into several smaller operations for the purposes of qualifying for PE exemptions. Ireland also intends to adopt the anti-avoidance rule in Article 14 which is designed to prevent contractual arrangements being made in a manner which artificially prevents a long-standing building site from being classified as a PE. Article 15 describes the conditions under which a person will be considered to be closely related to an enterprise for the purposes of Articles of the MLI. As Ireland has not made a reservation on Articles 13 or 14 entirely, Article 15 would apply for the purposes of those Articles. Dispute resolution Article 16 sets out standard time limits and procedural rules for how disputes under CTAs should be addressed. This is a minimum standard which Ireland will adopt. In keeping with the combined intentions of the BEPS project to prevent base erosion and profit shifting and also ease tax dispute resolution process and procedures, Ireland will allow unilateral adjustment of the amount of tax paid by a taxpayer in certain cases. This is provided for in Article 17 of the MLI. Articles consider mandatory binding arbitration. Countries must first decide whether to opt into these articles and if they do, they must adopt or reserve on a number of articles dealing with how arbitration would operate. Ireland was part of the ad-hoc group that developed the new optional provisions for mandatory binding arbitration and consequently is a signatory to Articles on mandatory binding tax treaty arbitration. Ireland has also signed up for the default type of arbitration, i.e., last best offer, also known as baseball arbitration. Other considerations As mentioned above, the positons taken by Ireland on the MLI were generally in line with expectations. Specific points to note in the context of larger multinational groups with operations in Ireland include: Reservations on certain contentious elements of the new PE rules. This could be linked to Ireland s tax certainty initiative which is part of Ireland s inward investment strategy. Adoption of the PPT in order to limit tax treaty benefits in circumstances where obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit. Adoption of mandatory binding treaty arbitration to assist taxpayers with disputes where no agreement can be reached between competing authorities.
4 4 Global Tax Alert Implications It is important to bear in mind that the signing of the MLI does not of itself make it effective with respect to Ireland s tax treaties. The MLI will need to be ratified by Ireland domestically. This could happen as soon as the Finance Bill 2017 which will be published in the autumn. Until ratification, individual country positions on the MLI, including that of Ireland, are subject to change. Once ratified by Ireland, the provisions of the MLI may potentially apply to all 71 CTAs of Ireland covered by the MLI but only to the extent that there are matching positions with other jurisdictions. The provisions which both countries have mutually opted for will come into force automatically three to four months after both parties to the treaty have ratified the MLI. The date of entry into effect varies depending on the specific tax provision. The MLI is a far-reaching initiative in international tax and should be an important consideration in the context of all new structures and transactions and also in reviewing current structures. It is possible that the changes made as a result of being a party to the MLI would be effective in 2019, though some CTAs may be affected as early as sometime in As mentioned above, it is also important that the interaction of the MLI with domestic rules is reviewed when considering its impact on a given structure or transaction. Endnotes 1. See EY Global Tax Alert, Signing by 68 jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS highlights impacts for business to consider, dated 14 June Switzerland can still include the treaty as a Covered Tax Agreement in advance of ratification. If this happens, the treaty will become a Covered Tax Agreement. Further, Switzerland and Ireland could also take the bilateral approach and negotiate a protocol/new treaty to meet the BEPS minimums standards. 4. Option A under Article 13 provided that certain exemptions from PE status would be exempt but only where the activities were preparatory or auxiliary in character. For additional information with respect to this Alert, please contact the following: Ernst & Young (Ireland), Dublin Aidan Walsh aidan.walsh@ie.ey.com Ciarán Conroy ciaran.conroy@ie.ey.com Ernst & Young, Financial Services (Ireland) EMEIA, New York Siobhan Dillon siobhan.dillon1@ey.com
5 Global Tax Alert 5 Appendix 1 Ireland s List of CTAs Albania Armenia Australia Austria Bahrain Belarus Belgium Bosnia and Herzegovina Botswana Bulgaria Canada Chile China Croatia Cyprus Czech Republic Denmark Egypt Estonia Ethiopia Finland France Georgia Germany Greece Hong Kong Hungary Iceland India Israel Italy Japan Korea Kuwait Latvia Lithuania Luxembourg Macedonia Malaysia Malta Mexico Moldova Montenegro Morocco New Zealand Norway Pakistan Panama Poland Portugal Qatar Romania Russia Saudi Arabia Serbia Singapore Slovak Republic Slovenia South Africa Spain Sweden Switzerland Thailand Turkey United Arab Emirates Ukraine United Kingdom United States Uzbekistan Vietnam Zambia
6 EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organization, please visit ey.com EYGM Limited. All Rights Reserved. EYG no Gbl NY ED None This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice. ey.com
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