Section 110 companies are Irish special purpose vehicles (SPVs) established as ‘qualifying companies’ under section 110 of the Irish Taxes Consolidation Act 1997 (as amended). Provided they meet certain conditions, such companies can conduct their activities and participate in financial transactions on a tax neutral basis.
Pearse Trust Blog
Companies which are resident in Ireland are chargeable to Irish Corporation Tax on their worldwide profits and capital gains. In order for such companies to comply with the filing and payment obligations under Irish tax law, all companies are required to file a Corporation Tax Return for each accounting period.Read More
Ireland’s tax system is sometimes criticised by those campaigning against corporate tax avoidance. However, what is often overlooked is the fact that Ireland’s low rate of corporate tax attracts high volumes of physical investment.
Ireland’s decision to join the EU in 1973 marked the introduction of Value Added Tax (VAT). VAT was implemented among all member states as the turnover tax within the “common market”, and as a means of policing VAT, the ‘VAT Information Exchange System’ (VIES) was introduced in 1993.
VIES operates as a system of administrative support to member states and ensures both the registration of companies for VAT as well as the correct rate of VAT being charged on all transactions.Read More
This blog will examine the tax considerations in relation to loans to participators. This anti avoidance measure attacks the practice of withdrawing profits from close companies in the form of loans. Without this measure it would be possible for shareholders in close company to borrow money from the company instead of taking remuneration or dividends.
The Irish Government has courted international controversy with its proposal for a preferential tax regime for income derived from intellectual property, known as the Knowledge Development Box (“KDB”). This blog post will discuss the outline of the proposal.
The proposed KDB is in line with the commitment contained in the Road Map for Ireland’s Tax Competitiveness, which was published in October 2014 alongside the Irish Government’s Budget for 2015. It was noted in the document that the global economy is evolving and business assets resulting from investment in “knowledge-based capital”, such as intellectual property, are becoming a significant driver of economic growth in OECD economies.Read More
Ireland’s Special Assignee Relief Programme (“SARP”) is a tax relief designed to boost the relocation of key talent to Ireland. The new SARP was introduced in 2012 to assist Irish companies and multinational companies in attracting key employees to Ireland. Where qualifying employees relocate to Ireland, SARP allows income tax relief in the form of a tax deduction from employment income.
The good news is that the Irish Finance Act 2014 has made a number of improvements to the relief which has allowed for the SARP to be available to a larger group of key talent relocating to Ireland since 1 January 2015.
There have been continuous improvements to Ireland’s Research and Development (“R&D”) Tax Credit since its introduction in 2004.
The 2015 Budget also made a major amendment to the R&D Tax Credit. The 2003 “base year” will be removed entirely from 1 January 2015.
The 2013 Act, which amended the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (the “2010 Act”), was introduced to allow Ireland to cooperate further with the recommendations of the Financial Action Task Force (“FATF”) and to incorporate the State’s experience in the area since the introduction of the 2010 Act.
On 14 October 2014, the Minister for Finance Michael Noonan, delivered Ireland’s Budget for 2015. As part of the Budget package, the Minister also published a Road Map “to secure Ireland’s place as the destination for the best and most successful companies in the world”.
The favourable provisions introduced in the Budget increase the attractiveness of Ireland as a location to carry on business and also improve the transparency of Ireland’s tax regime.
A summary of the advantageous measures incorporated in the Budget are as follows: