No current committee memberships matched for this official.
Intent: To exchange views on a range of administrative matters.
Details: General meeting between the Institute's Council & Executive Team and Revenue's Board & its Management Committee.
Intent: To discuss matters relating to international tax including Revenue guidance on the participation exemption for certain foreign dividends, outbound payments defensive measures and Pillar Two - global minimum tax.
Details: Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting will be published by TALC).
Intent: To discuss the Finance Bill 2025 amendments relating to the Participation Exemption for Foreign Dividends and Part 4A TCA 1997 (Pillar Two Rules).
Details: Meeting of the TALC BEPS Implementation Sub-committee. (The minutes of this meeting will be published by TALC).
Intent: Clarification on the policy rationale for the application of this rule regarding withholding tax in the context of section 831B TCA 1997.
Details: We raised our concerns regarding the application of withholding tax and exclusion of entities from the participation exemption for certain foreign distributions where a partial or nominal refund of tax applied as announced in Finance Bill 2025.
Intent: Clarification on how a branch can get a deduction for a non-trapped loss where a deduction was initially denied under hybrid rules.
Details: Requested Revenue to provide guidance on the treatment of loss-making branches and the double deduction rules in the context of non-trapped loss situations.
Intent: Overcome uncertainty on treatment regarding updates to Pillar 2 OECD guidance.
Details: Requested Revenue to provide guidance on what is considered a clarification or a supplemental rule in updates to Pillar 2 OECD guidance.
Intent: Clarification for securitisation vehicles on liability to top up tax under Pillar 2 legislation.
Details: Requested Revenue confirm that a securitisation vehicle will not be secondarily liable for domestic top up tax.
Intent: Clarification for orphan securitisation vehicles in relation Pillar 2 legislation.
Details: Requested Revenue to update guidance on the application of Minority Owned Constituent Entity provisions to orphan securitisation entities.
Intent: A range of Base Erosion and Profit Shifting (BEPS) issues are discussed at these TALC subcommittee meetings. Legislation and policy can be discussed in addition to administrative matters.
Details: TALC BEPs Meeting on 29 April
Intent: A range of Base Erosion and Profit Shifting (BEPS) issues are discussed at these TALC subcommittee meetings. Legislation and policy can be discussed in addition to administrative matters.
Details: TALC BEPS Sub-Committee Meeting
