Financial services tax

In recent years, Irish financial services companies have faced a myriad of tax challenges, navigating an ever-evolving landscape shaped by international regulations and domestic economic policies. As a hub for global financial services, Ireland has attracted a significant number of multinational corporations, but this influx has also brought forth complex taxation issues.

Navigating BEPS and Pillar Two

Irish financial services companies face significant change under the OECD’s Base Erosion and Profit Shifting (BEPS) framework and global tax reform initiatives such as Pillar Two.

These measures aim to align taxation more closely with where economic activity and value creation occur, while establishing a global minimum corporate tax rate. For many Irish financial firms, this means reassessing group structures, transfer pricing arrangements and profit allocation methodologies to ensure compliance and minimise risk exposure.

Transfer pricing

Transfer pricing remains a key focus for both businesses and tax authorities. Irish financial services firms must demonstrate that intercompany transactions – including loans, guarantees and management services – are conducted on an arm’s length basis.

Achieving this balance between regulatory compliance and tax efficiency requires robust documentation, regular policy reviews and alignment with evolving international standards to enhance transparency and reduce potential disputes.

Digital taxation

The continued digitalisation of financial services presents new and complex tax considerations. As digital business models evolve faster than global consensus, Irish financial institutions must adapt to emerging rules governing digital taxation and reporting.

These developments often require investment in technology to track digital transactions, implement new compliance systems and maintain comprehensive audit trails. Staff training and cross-functional collaboration among tax, legal and technology teams are essential to managing risk and ensuring accurate reporting.

Post-Brexit structuring 

Since the United Kingdom’s departure from the EU, many financial institutions have established their EU headquarters in Ireland to maintain access to the Single Market and passporting rights. Several years on, it is now timely to reassess these structures to ensure they remain efficient, compliant and aligned with broader strategic goals.

How we can help

Our experienced tax professionals work with a wide range of financial services clients — including banks, insurers, asset managers, securitisation vehicles, and aircraft lessors. We provide tailored tax planning and compliance solutions that minimise risk, enhance efficiency and support growth. 

As a global network, Forvis Mazars is ideally suited to serve both international and domestic financial services groups looking to expand into new markets.

Our services

Tax compliance and reporting

• Corporate tax compliance.
• Operational tax obligations.
• Payroll services.
• VAT and indirect taxes.
• Research and development tax credit claims.

International tax and structuring

• Advice on establishing in Ireland.
• Cross-border mergers and acquisitions.
• Withholding tax advisory.
• Foreign tax credits.
• Structuring foreign offices and funding.
• Managing effective tax rates and transaction timing.

Advisory and specialist support

• Risk analysis on BEPS, ATAD and Pillar Two developments.
• Transfer pricing advisory.
• Tax controversy and litigation support.
• Global mobility and employment tax guidance.
• Research and development tax credits.

Contact us 

Contact us today to learn how Forvis Mazars can be your strategic partner in navigating the evolving financial services tax landscape.