Ireland takes next step in tackling aggressive tax planning through work with OECD -Minister Donohoe

29th January, 2019

Ireland deposits Instrument of Ratification & final Multilateral Instrument with the OECD to give effect to BEPS recommendations


The Minister for Finance and Public Expenditure and Reform, Paschal Donohoe TD, today (Tuesday) welcomed the deposit with the OECD of Ireland’s Instrument of Ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to prevent BEPS (Multilateral Instrument).   

The OECD developed the Multilateral Instrument to apply many of the BEPS Recommendations to the approximately 3,000 bilateral tax treaties in place worldwide and prevent the need to renegotiate each one individually.

Commenting on the deposit of the Multilateral Instrument, Minister Donohoe said: ‘This is another example of the action Ireland is taking to tackle aggressive tax planning.  Ireland has always believed that aggressive tax planning is best addressed through co-operative multilateral agreements and I am delighted that we are depositing our Instrument of Ratification with the OECD today.  Once the Instrument is in force, it will significantly reduce opportunities for tax treaty abuse including bringing about the end of the so called “Single Malt” structure.  This completes the delivery of another important commitment set out in Ireland’s Corporation Tax Roadmap.’

The most important changes to Ireland’s treaties under the Multilateral Instrument will be the introduction of strong anti-avoidance rules that should prevent treaty benefits being claimed inappropriately.

The Multilateral Instrument also puts in place the final element necessary to end the so called “Single Malt” structure following the signature of a Competent Authority Agreement by the Maltese and Irish authorities last November.

Ireland remains committed to international tax reform and to continuing the implementation of new robust global standards that will ensure our corporation tax code is sustainable in the long run.




Notes for Editors

The OECD BEPS Multilateral instrument provides a mechanism to allow countries implement key BEPS Recommendations by modifying the application of their existing bilateral tax treaties.

Together with the Instrument of Ratification, Ireland deposited its Final Position on the Multilateral Instrument which was agreed by Dáil Éireann in Finance Act 2018. The Instrument will now come into effect in respect of Ireland’s bilateral tax treaties in line with the timelines set out in the Instrument.

The deposit of these documents completes the process which started in November 2016 when, following extensive negotiations, Ireland, together with over 100 jurisdictions, agreed to the Multilateral Convention.  Finance Act 2018 included the final legislative step to enable Ireland to make and deposit this Instrument of Ratification.

Ireland has 74 tax treaties and the Multilateral Instrument will modify the application of the majority of these treaties to ensure they are BEPS compliant without the need for separate bilateral negotiations.