Tax Facts 2019 - PwC
Tax Facts
2019
pwc.ie/taxfacts
Index
Tax Facts 2019 - Introduction
Tax Facts 2019 - Editor's page
Tax Policy Developments Policy OECD BEPS EU Domestic changes
Business taxation Corporation tax Corporation tax rates Losses Branch income Capital Gains Company residence R&D credit Intellectual property tax deduction Knowledge Development Box Tax depreciation Leasing Ireland as a holding company location Closely held companies Start-up companies Corporate ? Tax administration
Transfer Pricing Overview Transfer Pricing Compliance Review Country-by-Country Reporting Advance Pricing Agreements Mutual Agreement Procedure (MAP) Coffey Report Recommendations
Tax Facts 2019
1 Financial services
19 Relevant contracts tax (RCT)
34
Banking and treasury
19 Wide scope of RCT
34
2 Insurance Aircraft leasing
19 Operation of RCT
34
20
Aviation Sector Capital allowances for aviation services 3
20 Interest
36
Section 110 companies 3
20 Interest paid/payable
36
3
Real Estate Investment Trusts (REIT)
21 Loans to finance corporate acquisitions / investment
36
3
Asset management
22 Loans to acquire Interest in a Partnership
36
3
Irish Real Estate Funds
23 Deposit interest retention tax (DIRT)
37
Global Information Reporting (FATCA & CRS)
23 DIRT & First Time Buyers
37
Islamic Finance
24
5
5
Local Property Tax
38
5 Corporate - withholding taxes (WHT)
26 LPT Rates
38
5
Dividend WHT
26 Returns
39
5
Interest WHT
26 Late Payment/Non-Compliance
39
5
Royalties WHT
26
7
WHT on capital gains
7
Professional services withholding tax (PSWT)
8
WHT rate reductions and exemptions
26 27 Income tax
27 Main personal tax credits and reliefs
Main tax allowances
40 40 41
9
Income tax exemption limits
41
10 Tax treaties
28 Income tax rates
41
11 Multilateral Instrument
28 Maternity Benefit
42
12
Alimony/maintenance payments
42
13 Value added tax (VAT)
29 Personal Insolvency
42
13 General
29 Remittance basis of taxation (RBT)
42
13 Accounting for VAT
29 Domicile levy
43
Rates
29 Special assignment relief programme (SARP)
43
16 Exempt activities
30 Cross border workers
43
16 Property
30 Foreign earnings deduction (FED)
44
16 Section 56 Authorisation (formerly Section 13A)
30 Employment & Investment Incentive / Startup Refunds for
16 Withdrawal of VAT credit for bills not paid within six months
30 Entrepreneurs (SURE) / SCI
44
16
R&D tax credit
45
17 Stamp duty
32 Relief for mortgage interest payments
45
17 Rates
32 Rent relief for private accommodation
46
Transfer/purchase of residential property
32 Rent a room scheme
46
Transfer/purchase of other property
32 Rental income
46
Exemptions and reliefs
33 Help To Buy Incentive (HTB)
46
ii
Index
Home Renovation Incentive (HRI)
46 Universal Social Charge
58 Local taxes
69
Living City Initiative
47 The Universal Social Charge (USC)
58 Environmental Taxes
69
High Earner's Restriction
48
Employment of a carer
48 Pension schemes
59
Customs and excise
70
Childcare Services Relief
48 Pension contribution rules ? for employers
59 Customs
70
Self assessment - payment and returns
48 Pension contribution rules ? for individuals, the earnings limits
59 Excise
70
Pension contribution rules ? for individuals, the age related limits
59
Employee taxation Termination payments Benefits-in-kind (BIKs) - general BIK on company cars BIK on preferential loans BIK on professional subscriptions
Pension changes for public servants
60
50 Pension distribution rules occupational pension schemes ?
Tax contacts
72
50 the maximum pension allowed
60
50 Pension distribution rules ? occupational pension schemes ?
Appendix 1
74
50 the maximum lump sum allowed
60
51 Pension distribution rules ? PRSA and personal pensions
Withholding tax on payments from Ireland 61
74
51 Pension distribution rules ? Approved Retirement Funds (ARFs)
Withholding tax on payments from Ireland (continued) 61
75
BIK on travel passes and small benefits
51 Treatment of ARF Distributions for Double Taxation Agreements
62
Travel and subsistence
51 Limited access rules for Additional Voluntary Contributions (AVCs)
62 Appendix 2
76
Motor travel rates
52
Withholding tax on payments to Ireland
76
Subsistence rates - within Ireland
52 Capital gains tax
63 Withholding tax on payments to Ireland (continued)
77
Travel and subsistence expenses for Non-Executive
Rates
63
Directors (NEDs)
52
Losses
64
Exemptions and reliefs
64
Employee share schemes
52 Impact of debt write-off
66
Unapproved employee share schemes
53 Self-assessment ? payment and returns
66
Revenue approved employee share schemes
53
Employer reporting requirements
54
Capital acquisitions tax
67
Tax treatment of loans from employee benefit schemes
54
General
67
PRSI Rates Employee/Employer PRSI (Class A) Self-employed PRSI (Class S) PRSI classification of working directors
Calculation of CAT
67
56 Self-assessment ? payment and returns
67
56 Main exemptions
67
56 Main reliefs
68
56 Discretionary trust
68
57
Tax Facts 2019
iii
Index
Introduction
Welcome
Tax Policy Developments
Business taxation
Transfer Pricing
Financial Services
Corporate - withholding taxes (WHT)
Tax treaties
Value added tax (VAT)
Stamp duty
Relevant contracts tax (RCT)
Interest
Local Property Tax
Income tax
Employee taxation
Employee share schemes
PRSI
Universal Social Charge
Pension schemes
Capital gains tax
Capital acquisitions tax
Local taxes
Customs and excise
Tax contacts Appendix 1 Appendix 2
Tax Facts 2019
Withholding tax on payments from Ireland
Withholding tax on payments to Ireland
Tax Facts 2019 - The essential guide to Irish tax
Introduction This publication is a practical and easy-to follow guide to the Irish tax system. It provides a summary of Irish tax rates as well as an outline of the main areas of Irish taxation. A list of PwC contacts is provided within each tax area and at the back of this guide should you require more detailed advice or assistance tailored to your specific needs.
Joe Tynan Tax and Legal Services Leader
1
Index
Introduction
Welcome
Tax Policy Developments
Business taxation
Transfer Pricing
Financial Services
Corporate - withholding taxes (WHT)
Tax treaties
Value added tax (VAT)
Stamp duty
Relevant contracts tax (RCT)
Interest
Local Property Tax
Income tax
Employee taxation
Employee share schemes
PRSI
Universal Social Charge
Pension schemes
Capital gains tax
Capital acquisitions tax
Local taxes
Customs and excise
Tax contacts Appendix 1 Appendix 2
Tax Facts 2019
Withholding tax on payments from Ireland
Withholding tax on payments to Ireland
Tax Facts 2019 ? Editor's page
Welcome to the latest edition of Tax Facts which has been updated for amendments brought about by Finance Act 2018 which was signed into law on 19 December 2018.
From a personal tax perspective, Finance Act 2018 has made a number of adjustments to the tax bands, tax credits and USC rates which provide modest income tax savings for individuals. From an employer perspective, the next phased increase to the employer PRSI charge from 10.85% in 2018 to 10.95% is effective from 1 January 2019. This will further increase to 11.05% in 2020.
The Finance Act has made a number of amendments to the Employment and Investment Incentive (EII) scheme, which provides income tax relief for investment in certain corporate trades. The amendments should encourage take-up of the scheme and simplify the Revenue approval process. The Act also introduces a new Start-Up Capital Incentive ("SCI") which is targeted at early stage micro-companies.
From a VAT perspective, a number of goods and services which were previously subject to VAT at 9% are subject to VAT at 13.5% (with certain exceptions) with effect from 1 January 2019. Goods and services impacted by this change include restaurants, hotels, holiday accommodation and admissions to cinema, theatre or other cultural events. The 9% VAT rate has also been extended to the supply of electronic publications.
Finance Act 2018 introduces accelerated wear and tear allowances for gas vehicles and refuelling equipment used for trading purposes. Amendments are also made to the new accelerated capital
allowances regime which was proposed in Finance Act 2017 to grant employers capital allowance relief on the capital cost of constructing and equipping qualifying fitness or childcare facilities provided for use by employees of the employer. The amended regime commenced on 1 January 2019. The regime governing wear and tear allowances for certain energy efficient equipment has also been streamlined in order to make it more administratively effective.
Finance Act 2018 also contains a number of provisions which give effect to internationally agreed measures under the EU's Anti-Tax Avoidance Directive ("ATAD").
Controlled Foreign Company ("CFC") rules are introduced into Irish tax law for the first time and apply for accounting periods beginning on or after 1 January 2019. Subject to certain exemptions, the CFC rules tax an Irish group entity on the amount of undistributed profits of a CFC which can reasonably be attributable to certain activities that are carried on by that entity in Ireland.
A new exit tax regime became effective for transactions on or after 10 October 2018, replacing in full the existing exit tax provisions. The new exit tax rules are broader than before. Subject to certain anti-avoidance provisions, the tax rate applicable to any chargeable gain arising is 12.5%.
The Irish Government also ratified Ireland's choices under the Multilateral Instrument ("MLI") as part of Finance Act 2018. The MLI will come into effect in Ireland from 1 May 2019.
For more information contact:
Fiona Carney Director t: +353 (0)1 792 6095 e: fiona.carney@
Fiona Carney Director Tax Solutions Centre
2
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