The current position in relation to Master File, Local File and CbCR requirements are as follows:
› less than 250 employees; and either
› revenue not exceeding EUR 50 million; or
› total assets not exceeding EUR 43 million.
The Finance Act 2021 (applying from 1 January 2022) provides that the OECD approach to attribution of branch profits of non-resident companies is to be implemented. Non-trading transactions (in certain circumstances) between associated periods which are both within the charge for Irish tax remain exempt from TP considerations. It further clarifies that there does not need to be consideration for the exemption to apply.
The OECD approach to branch and permanent establishments is now required. Exemptions are in place where profits are less than EUR 250,000, however in the absence of this exemption the documentary requirements regarding compliance must be strictly observed.
With this newsletter, we inform multinational companies on country-specific and international legislative documents and regulations.
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