Financial Services Tax Newsletter February 2025

Welcome to the latest edition of the BDO Financial Services Tax Newsletter, where we bring you key updates and insights on tax developments within the Financial Services industry.

In this issue, we explore how the shifting political landscape is shaping tax and investment strategies, both in Ireland and abroad. With a new government in Ireland and a new president in the White House, the backdrop for tax policy continues to evolve.

One key highlight in this edition is the recently published Funds Sector 2030 report, which outlines 42 important recommendations aimed at enhancing the sector. My colleague Lee Kavanagh offers a detailed analysis, shedding light on the report’s suggestions, including ways to encourage more retail investment in Ireland and reforms to the taxation of Irish-domiciled funds.

We also take a closer look at Finance Act 2024, which introduced some significant changes to the Financial Services sector, including the introduction of the Participation Exemption for Foreign Dividends and some key amendments regarding Pillar II and its impact on investment undertakings and securitisation entities.

Additionally, the re-election of President Trump has sparked considerable discussion around its potential effects on the Irish economy. Colleagues Carol Lynch and Derek Henry provide insights into the ongoing conversation about tariffs and the importance of safeguarding foreign investment in Ireland.

As always, we hope you find this issue both informative and thought-provoking. Should you wish to discuss any of these topics in more detail, please don’t hesitate to reach out to me or my team. We’re here to help.


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Fund Sector 2030                                                 

The Funds Sector 2030 report proposes tax reforms to boost retail investment in Ireland, including removing the 8-year deemed disposal rule, aligning tax rates with CGT, and introducing limited loss relief. Other key measures include eliminating the 1% life assurance levy and simplifying offshore fund taxation to enhance investor appeal.

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Securitisation & QDTT                                      

Finance Bill 2024 introduces a partial exemption from QDTT for securitisation entities, following the OECD’s “Inclusion with Tax Collection” approach. While securitisation entities remain under QDTT, the tax liability is shifted to other group entities in Ireland. If no other entities exist, the securitisation entity remains liable for QDTT.

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Finance Bill 2024                                                 

Finance Bill 2024 introduces a Participation Exemption for foreign dividends and refines Pillar Two rules for investment undertakings and securitisation entities. Key updates include leasing amendments, outbound payment rule clarifications, Interest Limitation Rule refinements, and an extension of the revised bank levy to 2025.

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Derek Henry on Irish Election: US Ties and Housing Crisis Solutions

Derek Henry, Head of Tax, highlights key post-election issues in International Tax Review, emphasising the impact of the US election on foreign investment and Ireland’s housing crisis. He expects policy stability with the returning government and anticipates tax measures to boost housing supply through new construction and repurposing initiatives.

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Tariffs                                                                                                                 

The November Finance Dublin examines potential risks to Irish corporate tax revenues from US tariff policies and a proposed 15% corporate tax rate. With Irish exports to the US growing, concerns arise over potential new tariffs. Businesses are advised to assess risks and explore mitigation strategies amid evolving global trade dynamics.                            

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BDO Global Corporate Tax News | Issue 72 November 2024

The final 2024 issue of Corporate Tax News covers new investment incentives in Argentina and Indonesia, ongoing Pillar Two developments, and key tax changes worldwide. Highlights include Bahrain and Brazil’s QDMTTs, tax reforms in Colombia and the UK, and updates on withholding tax rules in Canada, Korea, and Norway.

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BDO Global Transfer Pricing News | Issue 49, December 2024

The OECD’s Pillar One, Amount B took a major step forward with new IRS guidance and OECD resources to support its implementation. The Netherlands and Spain also weighed in, while Australia advances public CbC reporting. Other updates cover India’s transfer pricing ruling and key takeaways from TP Minds Australia 2024.

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BDO Global Employer Services News | January 2025

BDO’s Global Employer Services News highlights key updates for international assignees, focusing on tax and social security. Developments include changes to company car benefits in Belgium, foreign trust reporting in France, employment tax changes in Germany, and updates to inpatriate tax regimes in Italy, Luxembourg, UK.

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BDO Global Employer Services News | December 2024

The publication provides updates on international assignee issues, with a focus on tax and social security. Recent highlights include new tax measures in Belgium, proposed stock option changes in Canada, 30% ruling adjustments in the Netherlands, and employment measure updates in the UK.                                   

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VAT in the Digital Age - updates and implications for your business

The EU's VAT in the Digital Age (VIDA) package introduces key changes, including mandatory e-invoicing, digital reporting, platform economy rules, and a single VAT registration system. Effective from 2028, these measures will simplify VAT compliance but require businesses to adapt their systems to meet new requirements.

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BDO Indirect Tax News                                    

The EU mandates e-invoicing for cross-border transactions from 1 July 2030. Businesses must ensure VAT compliance, system compatibility, and data accuracy. While simplifying reporting and reducing fraud, the shift poses challenges. Early preparation is key to handling diverse country-specific rules.

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BDO Global Indirect Tax News - Issue 1/2025

The latest Indirect Tax News explores global trade and VAT developments for 2025. Key topics include potential US tariffs, new VAT laws in China and Vietnam, EU VAT changes under the ViDA package, and e-invoicing updates across Europe. Additionally, new reporting obligations impact digital platform operators in Canada and the US.

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Amount B - recent guidance issued by OECD

The OECD has released new guidance on Amount B, including a pricing tool and IRS updates. With implementation set for 2025, businesses should assess potential impacts and prepare for evolving transfer pricing regulations.                                                                             

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Ireland's Exports Surge, but Trump’s Presidency and Trade Tensions with the US Loom Large

Ireland’s exports to the US surged in November, surpassing those to the EU. While positive, this growth may attract scrutiny from the incoming Trump Administration, requiring businesses to prepare for potential trade policy shifts in 2025.

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Supporting innovation in a competitive environment

Ireland's strong R&D landscape is driven by steady innovation, government support through enhanced tax credits, and collaboration with third-level institutions. These factors, along with strategic location and stable policies, contribute to competitiveness, job creation, and global innovation.

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