Tax Update - August 2025
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Joint Statement on the Framework for an EU / US Trade Agreement
On 21 August 2025, the EU and US issued their joint statement on the framework for an EU / US trade agreement following the announcement of a deal on tariffs and trade on 27 July 2025. The Commission has also issued a Q&A document.
In the joint statement, the EU and US have agreed:
On tariffs:
- A 15% US tariff rate (or, if higher, the most favoured nation rate) on all EU imports excluding aircraft and aircraft parts, generic pharmaceuticals and their ingredients and chemical precursors. This should in practice mean a maximum US 15% tariff rate on most EU imports to the US.
- The US intends to ensure that the US tariff rate on pharmaceuticals imported from the EU under the section 232 investigation does not exceed 15%. The joint statement also provides: “All modification to US Section 232 will be executed in a manner that reinforces and is consistent with US national security interests.” Currently, the US does not impose tariffs on pharmaceuticals so the maximum 15% rate will only begin to apply after changes are made (if any) to the US tariff system applying to pharmaceuticals on foot of the section 232 investigation.
- The US will reduce tariffs on automobiles and automobile parts once the EU eliminates all existing tariffs on US imports.
- The EU intends to eliminate tariffs on all US industrial goods.
Non-tariff barriers / EU regulation:
- The EU will address non-tariff barriers affecting trade in food, agricultural products and automobiles.
- The EU will take note of US concerns regarding the operation of the Carbon Border Adjustment Mechanism for US Small and Medium-sized Enterprises.
- The EU will undertake efforts to ensure the Corporate Sustainability Due Diligence Directive and Corporate Sustainability Reporting Directive do not impose undue restrictions on transatlantic trade and will work to reduce administrative burdens on businesses.
- The US and the EU commit to discussing IP rights protection and enforcement.
- The US and the EU commit to address unjustified digital trade barriers.
Commitments are also made by the EU to acquire more US energy and defence supplies and for EU companies to make new investments in the US.
Since the joint statement was released, President Trump has threatened new tariffs on countries with discriminatory digital regulation rules including digital taxes. The Q&A document issued by the Commission expressly provides that the joint statement does not include any commitment on digital regulations and notes that the Commission “made it very clear to the US that changes to our digital regulations… were not on the table.” The same document also includes a question about what the joint statement means for digital services taxes, to which the response is: “Nothing. The EU-US deal has no impact on Member States’ digital services taxes.”
The joint statement is the first step in a process and the EU and US will work to agree further zero-for-zero tariffs.
In response to the trade agreement, The Tánaiste and Minister for Foreign Affairs and Trade, Simon Harris, noted: “We welcome clarity that the deal includes a single, all-inclusive 15% tariff on EU goods….This provides an important shield to Irish exporters that could have been subject to much larger tariffs pending the outcomes of Section 232 US investigations into these sectors…. As the Statement makes clear, this is a framework agreement which gives us a first step to negotiate a more comprehensive and formal agreement with the US in the future. Our intention now is to see what other carve outs can be made in areas of interest for Irish exporters.”
Matheson LLP’s dedicated Customs and Trade Law team are monitoring developments closely in this area and assisting businesses to navigate the potential impact of new US tariffs.
Pillar Two Compliance
The Irish Revenue Commissioners (“Revenue”) have launched a dedicated Pillar Two webpage which includes basic information on the operation of Pillar Two, including key dates for registration and filing. The webpage also links to Revenue’s guidance on Pillar Two.
Tax Controversy and Dispute Resolution Updates
Evaluating Targeted Anti-Avoidance in Irish Tax Appeals
The recent TAC determination 58TACD2025 considered the application of a targeted anti-avoidance provision in the context of capital gains tax deferral relief in Ireland. The Matheson Tax team share their insights on this determination together with the key takeaways for taxpayers here.
R&D Tax Credit
The recent TAC determination 165TACD2025 considers a number of the legislative criteria which must be satisfied to claim the research and development tax credit in Ireland. The Matheson Tax team share their insights on this determination together with the key takeaways for taxpayers here.

