July 09, 2012 by admin in Blog
  • Comments Off on Irelands Transfer Pricing Rules

Irelands Transfer Pricing Rules

Finance Act 2010 introduced a formal transfer pricing regime for companies and branches within the charge to tax in Ireland on their trading activities for accounting periods commencing on or after 1 January 2011 in relation to any arrangement entered into on or after 1 July 2010. As discussed above,

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July 08, 2012 by admin in Blog
  • Comments Off on Ireland as a Holding Company Location

Ireland as a Holding Company Location

Following the introduction of a number of key taxation reliefs and exemptions in recent years, Ireland has become a very attractive place for MNCs to locate a holding company. I will go through each of the main tax incentives in turn. These incentives together with non-tax incentives such as those

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July 07, 2012 by admin in Blog
  • Comments Off on Ireland as a Financing Location

Ireland as a Financing Location

The 12.5% rate of corporation tax can also apply to group finance vehicles situated and operating in Ireland. Profits on interest earned in these financing activites qualify for the low corporate tax rate as long as the level of activity of the finance company is such that the company is

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July 05, 2012 by admin in Blog
  • Comments Off on Ireland’s IP regime

Ireland’s IP regime

Ireland introduced legislation providing extensive tax incentives for IP from May 2009 which encompasses a wide definition of IP. The new IP regime allows for the 12.5% trading corporate tax rate which applies in respect of trading operations to be reduced further by allowing for a tax deduction for interest

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July 04, 2012 by admin in Blog
  • Comments Off on Use Ireland to reduce the Group Effective Tax Rate

Use Ireland to reduce the Group Effective Tax Rate

Locating in Ireland can help to reduce the Effective Tax Rate (“ETR”) of International Groups Many MNCs currently wishing to structure European or European/AsiaPac operations efficiently to ensure that group ETR is minimised leverage Ireland’s low corporate tax rate to achieve this goal. One such structure used is the Central

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July 02, 2012 by admin in Blog
  • Comments Off on Using Ireland in international tax planning (introduction)

Using Ireland in international tax planning (introduction)

Ireland has developed a strong track record in attracting foreign direct investment from multi-National Companies (“MNCs”) operating in the Information and Communications Technology, Life Sciences and Financial Services sectors, including Digital Media, Engineering, Consumer Brands and International Services. One strong force pulling MNCs to choose Ireland as their strategic European

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