Further to the 2010 budget announced on December 09 2009 the following key changes have been announced in the Finance Bill published on 04 February 2010:

1. New transfer pricing provisions for  large associated companies with a requiremnet that they keep sufficient documentation to prove transactions were at ‘arms length’. SME’s have been excluded from the new provisions.
2. Improvements to the ‘intangible assets scheme’ by reducing to 10 years the period by which a ’specified asset’ must be used in the trade to avoid a clawback of allowances.
3. Foreign dividends paid out of profits of a company not reeisent in a treaty company to be taxed at 12.5% where this company is owned by a publicly quoted company.
4. Relief from balancing charges for cross border merger within EU.
5. Exemption form Irish witholding tax on royalty payments to individuals or permanent establishments based in EU or treaty countries
6. Removal of need for production of a certificate of tax residence or audit certificate  to Irish resident companies who are paying dividends to non-Irish resident companies thus  avoiding deduction of DWT. A new system to replace this will be introduced so that exemption form DWT can be claimed.
7. Corporate tax relief at 0% for start up companies confirmed for three years from 2010.
8. Proposal to abolish remittance basis of taxation for Irish domiciles who are non-ordinarily resident in Ireland. This means that Irish domiciles can no longer avail of the remittance basis for the current 3 year period whilst non-ordinarily resident.
9. Also stricter application of the remittance basis to individuals who are claiming non-Irish domiciled status. It appears that this means that revenue will be required to be satisfied as to a taxpayers domicile. It is unclear at this stage exactly what information they will require to support a taxpayers claim that they are non-domiciled.
10. The new domcile levy seeks to charge a minimum tax of  e200,000 to individuals whose Irish income tax liability is less than  e200,000, worldwide income is greater than e 1M andwhose Irish situated property more than e5m at 31/12 in the year concerned. Shareholdings are excluded from the definition of Irish property.
11. Mortgage interest relief to be abolished from 2018.
12. PAYE change for ‘proprietary directors’, who will  no longer be able to claim credit for PAYE until such time as the company pays the PAYE deducted to the Revenue Commissioners.
13. Pay and file to be introduced for CAT. The year will be split in two Jan to August and Sept. to December. If valuation date is Jan. to Aug. then pay and file date is 31/10 in the year concerned. Where valuation is Sept. to Dec. then filing date is 31/10 in following year.

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