1. EY Wealth report

The EY Global Centre for Wealth Management has recently published its biennial Global Wealth Research Report. This is a comprehensive global source of customer insight for the wealth management industry. Now in it’s 10th year, the 2025 Global Research Report draws on 30 key markets and 3,500 individuals across ultra High Net Worth, very High Net Worth, High Net Worth and core affluent. It also carries out a deep dive into investor needs across psychographics, generations, undeserved segments, advisory preferences, alternative assets, AI, wealth transfer and more. Access the report here.

2. Pillar Two Update

Multinational enterprises in the wealth and asset management space that are within the scope of BEPS Pillar Two should consider their readiness to register with the Irish tax authorities (‘Revenue’) by the end of this year. It is expected that Revenue will make their registration portal available from sometime in Q3 of this year, facilitating timely registration. Revenue are also expected to reach out to taxpayers who already file Country by Country Reporting details to ensure they have considered the impact of Pillar Two so taxpayers should be prepared to respond.

3. DAC 9

The EU Pillar Two Directive and implementing Irish legislation implementing allow for the central filing of the Top up Tax Information Return (Globe Information Return (GIR) under OECD model rules) provided that the return is made by the UPE or a designated filing entity located in a jurisdiction with which Ireland has a qualifying authority agreement.

4. US Tax Proposals – S.899

On 22 May 2025, the United States House of Representatives narrowly passed the One Big Beautiful Bill Act, which proposed to introduce a new Section 899 to the U.S. Internal Revenue Code. If introduced, s.899 would have significantly increased tax rates for certain non-U.S. individuals, businesses, and other entities connected to jurisdictions that impose “unfair foreign taxes” on U.S. individuals and businesses.
However, on 26 June, Congressional Republicans agreed to remove the retaliatory tax proposal – section 899 – from the House-passed and Senate-proposed versions of the Bill. This followed a request from Treasury Secretary Scott Bessent.

In parallel, G7 countries issued a joint statement confirming a shared understanding on the treatment of U.S.-parented groups under the OECD/G20 Inclusive Framework on Pillar 2 global minimum taxes. The agreement confirms that U.S. groups will be fully excluded from the Undertaxed Profits Rule (UTPR) and Income Inclusion Rule (IIR), recognising existing U.S. minimum tax rules.
The statement highlighted that this “side-by-side” system aims to preserve the progress made through the Inclusive Framework on tackling base erosion and profit shifting, while providing greater stability and certainty for international tax policy. Work will continue to finalise the system and address potential risks to the level playing field.

This development reflects the broader global and political uncertainty currently influencing international tax policy. We will continue to monitor developments and provide updates as further announcements are made.

This reflects the broader global and political uncertainty currently influencing international tax policy. We will continue to monitor developments and provide updates as further announcements are made.

5. ATAD 3 – Unshell Directive

There has been a recent development regarding ATAD 3 (the “Unshell Directive”), which was originally proposed by the Commission in December 2021 and which aims to combat “shell companies”. Despite negotiations since 2021, Member States have continued to disagree on this Commission proposals. Referring to overlaps with DAC6 and concerns about administrative burden, the Member States have now concluded not continue to work on Unshell.

6. FASTER: Streamlining Cross-Border Tax Relief in the EU

Earlier this year, the EU adopted the Directive Faster and Safer Relief of Excess Withholding Taxes (FASTER). This aims to streamline tax relief processes, encourage cross-border investment, and combat tax fraud. Member States must transpose the directive by 31 December 2028, with rules effective from 1 January 2030.

Key elements include:

• A common EU digital tax residence certificate for fast-track relief procedures.
• A choice between a “relief at source” system and a “quick refund” system, ensuring refunds within 60 days.
• Standardised reporting obligations for financial intermediaries, such as banks or investment platforms, to improve tax authority oversight.

The directive replaces outdated, paper-based processes with an electronic residence certificate, ensuring compliance and faster processing. Financial intermediaries will also face reporting obligations and liability for non-compliance with withholding tax procedures.

What you should consider now to prepare:

• Assess the impact on your business
  Are you a mandatory Certified Financial Intermediary (CFI)? If not, should you consider becoming a CFI? If you are an asset manager or asset owner, gather thoughts from your custodian on their plans for implementation.
  Conduct analysis to understand entities, business line and product impact
• FASTER implementation project ownership
  Determine what section of the business owns the project (defining project sponsor, budgets, resourcing)
• Stakeholder engagement — facilitate stakeholder discussion to allocate ownership and lock-in funding
• Regulatory change tracking — implement a change tracking tool to monitor local regulatory developments and updates from EU working groups

7. Withholding Tax Updates

Poland

Under Polish national law and in line with the established practice of Polish courts and the ECJ, most EU and non-EU investment and pension funds should be eligible for full exemption from tax on income sourced from Poland.

However, many funds still suffer WHT at the 19% or 20% standard rate chargeable on income from their Polish source investments, such as dividends or interest on corporate bonds. In some cases, they cap this tax claiming based on double tax treaty rate of 5%, 10% or 15%, either through relief at source or a reclaim procedure, yet they may still be overpaying WHT in Poland instead of applying the full exemption.

Eligibility for the exemption is subject to certain conditions, which are not automatic and require verification on a case-by-case basis. Therefore, in practice, Polish tax remitters rarely claim the exemption and, historically, the Polish tax authorities were reluctant to apply these exemptions, too. Notwithstanding, as our experience involving many successful appeals and favorable court cases shows, the application of such exemptions tends to be widely accepted now.

Recently issued CJEU’s judgement (case no. C-18/23) in Polish case indicates that even if domestic regulations of fund’s country of residence governing its establishment and operations differ from regulations of country of source of income, e.g. with regards to a legal form or method of management of a fund, these differences cannot lead to deprivation of a tax advantage. Therefore, non-Polish internally managed investment funds which overpaid tax in Poland should apply for WHT refund as soon as possible based on the positive CJEU’s judgement.

Foreign funds which invested in Poland between 2020 and 2025 and suffered tax on dividends, interest or capital gains from Poland (at a standard or double tax treaty rate) may seek and benefit from significant tax refunds. EY teams have already successfully supported numerous Irish and other EU and non-EU funds in obtaining full exemption from tax on income sourced from Poland. It is important to note that the opportunity for reclaiming the tax paid on 2020 incomes expires on 01/01/2026 (under the statute of limitations in Poland, tax liabilities become non-enforceable, in principle, after 5 years).

Belgium

The Belgian tax on collective investment undertakings, commonly referred to as the ‘Net Asset Tax’ (NAT), concerns (sub-)funds registered for distribution in Belgium. These investment vehicles owe the NAT on the total net amounts outstanding in Belgium on a certain reference date. The rate of the NAT depends on the nature of the investor (private or institutional).

The NAT has been the object of jurisprudential disputes ever since the introduction of the tax. The question at hand: does the NAT constitute a tax, more in particular a tax on capital, covered by the relevant DTCs? Only when answered affirmatively, taxpayers could argue that Belgium should refrain from imposing the NAT and file a claim for the reimbursement of NAT paid.

The Ghent Court of Appeal, in its judgement of 5 November 2024, ruled that the NAT constitutes a ‘tax on capital’, and the imposition of NAT on Luxembourg funds violates the Double Tax Convention (“DTC”) between Belgium and Luxembourg. Consequently, taxpayers are in principle eligible to reclaim the NAT paid from the tax authorities. Although this judgment is favourable for taxpayers, the Belgian state would most likely file an appeal with the Supreme Court, considering the financial impact of the judgement.

At this point in time, it is uncertain whether taxpayers will be able to reclaim the NAT based on the Luxembourg DTC. All eyes will be on the Supreme Court, which must rule on the matter once more. However, the timeline for issuing a judgment remains uncertain. Consequently, taxpayers must be vigilant regarding the statute of limitations which will expire two years after the payment of the tax. In order to suspend the statute of limitations, taxpayers are advised to file a reclaim in order to safeguard their rights.

France

In two pivotal decisions on December 5, 2024, and January 23, 2025, a French lower administrative court ruled that tax-exempt Irish pension funds qualify as Irish tax residents within the meaning of the France-Ireland Double Tax Treaty (“DTT”) and can benefit from the reduced withholding tax rate of 15% on French-source dividends, provided that the fund is “managed and controlled” in Ireland, in accordance with Article 2, paragraph 8 of the DTT.

For several years leading up to these decisions, the French tax authorities consistently denied treaty benefits to Irish pension funds, arguing that they were not considered Irish tax residents due to a strict interpretation of the “subject to tax” clause under Article 2, paragraph 7 of the DTT. However, the administrative court now considers that paragraph 8, i.e. ‘managed and controlled’, provides an alternative and autonomous criterion for tax residency. Please note that these decisions are still open for appeal by the French tax authorities.

Nevertheless, these rulings confirm an opportunity for any tax-exempt entity in Ireland to claim the reduced DTT rate on French-source dividends, provided that they are “managed and controlled” in Ireland. The Statute of Limitation to claim the French withholding tax is normally by December 31st of the second year following the dividend payment.

8. VAT Updates

VAT Recovery Rate Adjustments: Imminent deadline

Funds, managers, and service providers may be entitled to some Irish VAT recovery based on the proportion of their taxable activities and non-EU financial services activities relative to their total business activities.

For businesses with a 31 December 2024 year-end, it is critical to adjust any provisional 2024 VAT recovery rate to reflect the actual entitlement no later than the May/June 2025 VAT return, which is due on or before 23 July 2025. Failure to do so could result in interest charges and penalties.

If your business has not previously claimed any VAT recovery, now is also the time to reassess whether you have unclaimed VAT entitlements. Retrospective claims may be possible, unlocking significant recoveries. Our team of VAT experts have a proven track record of considering a range of VAT recovery rate methodologies and approaches and can assist you in this exercise.

Increased Revenue Activity: VAT Reviews and Audits

We have noted an increase in Revenue’s VAT audit and review activity since our last update. VAT audits are complex, time consuming and can present significant challenges for businesses in meeting tight deadlines, engaging with Revenue and the threat of publication on the tax defaulters list.

In our experience the better approach is to proactively review your VAT position and consider making an unprompted disclosure where appropriate. Early action can reduce the possibility of publication and exposure to higher penalties.

If you have been contacted in respect of a VAT audit/review or you would like to discuss undertaking a VAT review then please get in touch.

9. Country by Country Reporting

Public Country-by-Country Reporting

Public Country-by-Country Reporting (PCbCR) is an EU Directive that requires large multinational enterprises (“MNE”) to disclose key financial information (tax and non-tax related information) on a country-by-country basis. Businesses impacted are required to publicly disclose the information on a disaggregated basis, i.e., on a country-by-country basis, for all 27 EU Member States and all jurisdictions listed in the EU list of non-cooperative jurisdictions for tax purposes (similar requirements exist in respect of the Australian PCbCR rules). For rest of the world, the information can be disclosed on aggregated basis.

We want to draw your attention to the implementation in Ireland of the EU Directive 2021/2101 regarding PCbCR, through Statutory Instrument No. 322 of 22 June 2023. These rules apply to financial years beginning on or after 22 June 2024 and require MNE groups with consolidated revenue exceeding €750 million in two consecutive financial years to publicly disclose key financial information on a country-by-country basis. Reports must be made available on the company’s website within 12 months of the balance sheet date. For example, if the financial year-end of your company is June 30, the first financial year in scope of PCbCR requirements would be the year starting on 1 July 2024 and ending on 30 June 2025. Consequently, the deadline for publishing the report would be 30 June 2026. Similarly, the deadline for the Company with financial year ending on December 31, the first reporting deadline would be 31 December 2026. The obligations (and some exclusions) apply differently to different entities, depending on the facts and circumstances.

Rules may be slightly different in other EU member states. For example, some EU member states may be early adopters of the EU Directive, some countries may have shorter reporting period, there could also be difference in safeguard clauses, local exclusions, etc. Thus, the requirements should be carefully considered in the operating EU members states for the MNE group.

We are helping lot of companies undertaking analysis to assess which EU member states they may need to make disclosures and consider how their data will appear on a public forum based upon their 2024 year-end results (as a ‘dry’ run), given the commercial sensitivity around making such public disclosures. If you expect your MNE group to be in scope of PCbCR, we would be happy to assist in assessing your obligations and readiness or advise you in navigating any potential exemptions.

Common Errors in Private Country-by-Country Reporting

Tax administrations have encountered a number of concerns with the data in private country by country report (“CbCR”) filed to date. Recently OECD has published guidance on some common errors that tax MNE groups make when preparing CbCR. These errors can impact the accuracy and reliability of the reports submitted to tax authorities. Frequent issues include misclassification of entities, incomplete financial data, incorrect reporting of the revenue, usage of multiple currencies, inconsistencies between the CbCR and local financial statements, etc. Additionally, incorrect allocation of income and expenses can lead to misrepresentations of the multinational enterprise’s economic activities. It is also important to include correct tax identification numbers, as they help tax authorities use the CbCR data effectively. There are many other helpful points highlighted in the new OECD guidance issued on this topic.

MNE groups should review their reports and ensure that these errors are not repeated in the CbCR they are preparing. To mitigate these risks, we recommend implementing robust internal controls and review processes to ensure that all data is accurate, complete, and aligned with transfer pricing policies. Regular training and updates on common errors when preparing this report can further help reduce the likelihood of errors in future submissions. If you require assistance in reviewing your CbCR processes, our team is here to help.

Tax and Duty Manual on Transfer Pricing under consideration and amendment

The Tax and Duty Manual on transfer pricing is currently under consideration and amendment by Revenue. We will keep you posted on the key amendments and development once it is updated and released by the Revenue.

10. Common Reporting Standard and the Crypto – Asset Reporting Framework

The OECD has introduced significant amendments to the Common Reporting Standard (CRS) to enhance tax transparency and adapt to evolving financial technologies. These changes, effective beginning 1 January 2026, have practical implications for financial institutions.

Key Changes include

• Expanded Scope: The CRS now includes electronic money products ensuring broader coverage of digital financial assets.
• Crypto-Asset Integration: Indirect investments in crypto-assets—via derivatives or investment vehicles—are now reportable under CRS, aligning with the OECD’s new Crypto-Asset Reporting Framework (CARF).
• Enhanced Due Diligence: Financial institutions must implement onboarding procedures for digital and crypto-related accounts and update their current processes such that they can align with the new reporting requirements.
• Operational Adjustments: Institutions will need to update reporting systems, XML schemas, and internal processes to comply with the revised standards.

Practical Implications

• System Overhauls: Tax, Compliance and IT teams should begin reviewing and updating systems to accommodate new data fields and reporting formats.
• Staff Training: Enhanced due diligence requirements will necessitate updated training for onboarding and compliance teams.
• Service Providers: Financial institutions should be communicating with third-party service providers to ensure they are updating their systems and processes in line with the new CRS requirements.
• Client Communication: Institutions may need to inform clients—especially those dealing in digital assets—about new reporting obligations.