Research Repository
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Intellectual Property
World Corporate Top R&D Investors: Innovation and IP Bundles (A JRC and OECD common report. Luxembourg: Publications Office of the European Union), 2015
Read the Report here
World Corporate Top R&D Investors: Industrial Property Strategies in the Digital Economy, OECD Publication, 27th September 2017. Read the Report here
The OECD Regpat Database: A presentation STI Working Paper 2008/2 Statistical Analysis of Science, Technology and Industry, 2008/2. Read the Report here
Promoting intellectual property monetization in developing countries : a review of issues and strategies to support knowledge-driven growth, World Bank, 2014. Read the Report here
"What Problems and Opportunities are Created by Tax Havens?" Oxford Review of Economic Policy, Vol. 24 No. 4, Winter 2008. Read the Report here
Council Directive 2003/123/EC of 22 December 2003 amending Directive 90/435/EEC on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States. Read the Directive here
Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States. Read the Directive here
COUNCIL DIRECTIVE 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States. Read the Directive here
COUNCIL DIRECTIVE 2005/19/EC of 17 February 2005 amending Directive 90/434/EEC 1990 on the common system of taxation applicable to mergers, divisions, transfers of assets and exchanges of shares concerning companies of different Member States. Read the Directive here
The Netherlands
International aspects of taxation in the Netherlands, Belastingdienst. Read the overview here
Treaties for the avoidance of double taxation concluded by the Netherlands, Belastingdienst. Read the list here
Convention between the Kingdom of the Netherlands and Australia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, 1st March, 1976. Read the Treaty here
Convention between the Kingdom of the Netherlands and the Republic of Bangladesh for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, 1st January, 1995. Read the Treaty here
Agreement between the Netherlands and the People's Republic of China for the avoidance of double taxation, 31st May, 2013. Read the Treaty here
Convention between the Kingdom of the Netherlands and the Republic of India for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital, 1st January, 1989. Read the Treaty here
Tax treaty between Hong Kong and the Netherlands for avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, 22nd March, 2010. Read the Treaty here
The Convention between the United States of America and the Kingdom of the Netherlands for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect to taxes on income, 18th December 1992. Read the Treaty here
Agreement between the Kingdom of the Netherlands and the Republic of Poland on encouragement and reciprocal protection of investments. Read the Treaty here
Regulatory Reform in the Netherlands, OECD, 1999. Read the Report here
Tax Certainty, OECD, IMF/OECD Report for the G20 Finance Ministers, March 2017. Read the Report here
The Netherlands Issues Regulations on CbC Reporting Requirements, Thomson Reuters, January 2016. Read the Article here
Kingdom of the Netherlands, Selected Issues, IMF, January 2016. Read the Report here
Ireland
Commentary on Typical Provisions of Irish Tax Treaties. Read the Commentary here
Agreement between Ireland and the Republic of Albania for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 16th October, 2009. Read the Treaty here
Agreement between Ireland and the Republic of Armenia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 14th July, 2011. Read the Treaty here
Agreement between Ireland and Australia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st July, 1984. Read the Treaty here
Agreement between Ireland and the Republic of Austria for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th June, 1987. Read the Treaty here
Agreement between Ireland and the Kingdom of Bahrain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th October, 2009. Read the Treaty here
Agreement between Ireland and the Republic of Belarus for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 3rd November, 2009. Read the Treaty here
Agreement between Ireland and Belgium for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 24th June, 1970. Read the Treaty here
Agreement between Ireland and Bosnia and Herzegovina for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 3rd November, 2009. Read the Treaty here
Agreement between Ireland and Botswana for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 10th June, 2014. Read the Treaty here
Agreement between Ireland and the Republic of Bulgaria for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 5th October, 2000. Read the Treaty here
Agreement between Ireland and Canada for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 8th October, 2003. Read the Treaty here
Agreement between Ireland and the Republic of Chile for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 2nd June, 2005. Read the Treaty here
Agreement between Ireland and the Republic of China for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 5th October, 2000. Read the Treaty here
Agreement between Ireland and the People's Republic of China for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th April, 2000. Read the Treaty here
Agreement between Ireland and the Republic of Croatia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 21st June, 2002. Read the Treaty here
Agreement between Ireland and Cyprus for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 24th September, 1968. Read the Treaty here
Agreement between Ireland and Czech Republic for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st January, 2013. Read the Treaty here
Agreement between Ireland and the Kingdom of Denmark for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 26th March, 1993. Read the Treaty here
Agreement between Ireland and the Arab Republic of Egypt for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 9th April, 2012. Read the Treaty here
Agreement between Ireland and the Republic of Estonia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 16th December, 1997. Read the Treaty here
Agreement between Ireland and the Federal Democratic Republic of Ethiopia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 3rd November, 2014. Read the Treaty here
Agreement between Ireland and the Republic of Finland for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 6th April, 1990. Read the Treaty here
Agreement between Ireland and France for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st January, 1966. Read the Treaty here
Agreement between Ireland and Georgia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 20th November, 2008. Read the Treaty here
Agreement between Ireland and the Federal Republic of Germany for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 17th October, 1962. Read the Treaty here
Agreement between Ireland and the Hellenic Republic (Greece) for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 24th November, 2003. Read the Treaty here
Agreement between Ireland and Hong Kong for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 22nd June, 2010. Read the Treaty here
Agreement between Ireland and the Republic of Hungary for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 17th November, 1995. Read the Treaty here
Agreement between Ireland and the Republic of Iceland for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 17th December, 2003. Read the Treaty here
Agreement between Ireland and the Republic of India for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 3rd September, 2001. Read the Treaty here
Agreement between Ireland and the State of Israel for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st January, 1996. Read the Treaty here
Agreement between Ireland and Italy for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 11th June, 1971. Read the Treaty here
Agreement between Ireland and Japan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 18th January, 1974. Read the Treaty here
Agreement between Ireland and the State of Kuwait for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 23rd November, 2010. Read the Treaty here
Agreement between Ireland and the Republic of Korea for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 18th July, 1990. Read the Treaty here
Agreement between Ireland and the Republic of Kazakhstan (not yet in effect) for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 16th April, 2017. Read the Treaty here
Agreement between Ireland and the Republic of Latvia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 13th November, 1997. Read the Treaty here
Agreement between Ireland and the Republic of Lithuania for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 18th November, 1997. Read the Treaty here
Agreement between Ireland and the Grand Duchy of Luxembourg for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 14th January, 1972. Read the Treaty here
Agreement between Ireland and the Republic of Macedonia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 14th April, 2008. Read the Treaty here
Agreement between Ireland and Malaysia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 28th November, 1998. Read the Treaty here
Agreement between Ireland and Malta for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 14th November, 2008. Read the Treaty here
Agreement between Ireland and the United Mexican States for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 22nd October, 1998. Read the Treaty here
Agreement between Ireland and the Republic of Moldova for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 28th May, 2009. Read the Treaty here
Agreement between Ireland and Montenegro for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 7th October, 2010. Read the Treaty here
Agreement between Ireland and the Kingdom of Morocco for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 22nd June, 2010. Read the Treaty here
Agreement between Ireland and the Kingdom of the Netherlands for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 11th February, 1969. Read the Treaty here
Agreement between Ireland and New Zealand for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th September, 1986. Read the Treaty here
Agreement between Ireland and the Kingdom of Norway for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 30th July, 2001. Read the Treaty here
Agreement between Ireland and the Islamic Republic of Pakistan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 13th April, 1973. Read the Treaty here
Agreement between Ireland and the Republic of Panama for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 28th November, 2011. Read the Treaty here
Agreement between Ireland and the Republic of Poland for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 5th December, 1995. Read the Treaty here
Agreement between Ireland and the Portuguese Republic for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st June, 1993. Read the Treaty here
Agreement between Ireland and the State of Qatar for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 21st June, 2012. Read the Treaty here
Agreement between Ireland and Romania for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 21st October, 1999. Read the Treaty here
Agreement between Ireland and the Russian Federation for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 29th April, 1994. Read the Treaty here
Agreement between Ireland and the Kingdom of Saudi Arabia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th October, 2011. Read the Treaty here
Agreement between Ireland and the Republic of Serbia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 23rd September, 2009. Read the Treaty here
Agreement between Ireland and the Republic of Singapore for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 28th October, 2010. Read the Treaty here
Agreement between Ireland and the Slovak Republic for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 8th June, 1999. Read the Treaty here
Agreement between Ireland and the Republic of Slovenia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 12th March, 2002. Read the Treaty here
Agreement between Ireland and the Republic of South Africa for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 7th October, 1997. Read the Treaty here
Agreement between Ireland and the Kingdom of Spain for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 5th October, 1994. Read the Treaty here
Agreement between Ireland and Sweden for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 18th December, 1987. Read the Treaty here
Agreement between Ireland and the Swiss Confederation (Switzerland) for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 8th November, 1966. Read the Treaty here
Agreement between Ireland and the Kingdom of Thailand for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 4th November, 2013. Read the Treaty here
Agreement between Ireland and the Republic of Turkey for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 24th October, 2008. Read the Treaty here
Agreement between Ireland and the United Kingdom for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 2nd June, 1976. Read the Treaty here
Agreement between Ireland and Ukraine for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 19th April, 2013. Read the Treaty here
Agreement between Ireland and the United Arab Emirates for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 1st July, 2010. Read the Treaty here
Agreement between Ireland and the United States of America for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 28th July, 1997. Read the Treaty here
Agreement between Ireland and the Republic of Uzbekistan for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 11th July, 2012. Read the Treaty here
Agreement between Ireland and the Republic of Vietnam for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 10th March, 2008. Read the Treaty here
Agreement between Ireland and the Republic of Zambia for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income, 31st March, 2015. Read the Treaty here
A Guide to Changes in Irish Tax Rules, Irish Tax Institute, September 2016. Read the Guide here
Ireland, Changes to Irish Corporate Residence Rules, International Tax Review, December 2014. Read the Article here
Broadening the Irish Tax Base in 2013, Finola O’Hanlon, O’Hanlon Tax Limited, Ireland, January 2013. Read the Article here
Ireland’s Path to Recovery – Budgetary Measures 2012, Cormac Brennan, Partner, O’Connell Brennan Solicitors, Dublin, January 2012. Read the Article here
Some alternative locations in Europe for (tax free) residence outside the UK, Francis Hoogewerf, Hoogewerf & Cie, Luxembourg, January 2009. Read the Article here
Taking the First Bite: Who Should Tax Apple’s $187 Billion in Ireland?, University of Oxford, March 2017. Read the Article here
The OECD BEPS Project
Explanatory Statement 2015. Read the Report here
Action 1: Addressing the Tax Challenges of the Digital Economy. Read the Report here
Action 2: Neutralising the Effects of Hybrid Mismatch Arrangements. Read the Report here
Action 3: Designing Effective Controlled Foreign Company Rules. Read the Report here
Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments. Read the Report here
Action 5: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance. Read the Report here
Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. Read the Report here
Action 7: Preventing the Artificial Avoidance of Permanent Establishment Status. Read the Report here
Actions 8-10: Aligning Transfer Pricing Outcomes with Value Creation. Read the Report here
Action 11: Measuring and Monitoring BEPS. Read the Report here
Action 12: Mandatory Disclosure Rules. Read the Report here
Action 13: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting. Read the Report here
Action 14: Making Dispute Resolution Mechanisms More Effective. Read the Report here
Action 15: Developing a Multilateral Instrument to Modify Bilateral Tax Treaties. Read the Report here