As the Irish economy revamps, there has been plenty of work for tax advisers and Ireland remains an attractive market for investors due to its tax system. Traditionally, Ireland has attracted a lot of multinational investment, particularly from Britain, the rest of Europe and the US.
Since Ireland has a minority government it's unlikely that there will be major domestic changes in terms of tax laws. However, the country is open to changes at international level. This may leave the Irish market open to the impact of events in the US and the UK, as well as the EU.
However, while many countries are concerned that US President Donald Trump's plan to reduce corporation tax to 15% will result in competitive pressure among countries, the corporate tax rate set in Ireland is already below this. If there is a knock-on effect it will likely hit other OECD economies.
Then there are the questions around the UK's withdrawal from the EU (Brexit). What is clear at this point is that it means far more uncertainty for investors until the negotiations produce a deal. One consequence may be that Ireland would lose its major ally in the EU; the UK has long opposed certain European efforts to restrict tax avoidance and member states with low tax regimes are often the target of these efforts.
There has been an increase in legal work around tax controversies and foreign disputes. "I think the European tax authorities have more toys to play with," said Fintan Clancy, co-chair of Arthur Cox's tax group. "Ireland is probably going to be on the list because of its relationship with multinationals. Not [that] there's necessarily anything wrong going on here, it's just a matter of business."
Because the EU is pursuing the implementation of the Anti-Tax Avoidance Directive (ATAD), and as Ireland is a major destination for multinational companies, the Irish tax authorities are now expected to be far more vigilant. Ahead of the ATAD coming into effect on January 1 2019, the Irish tax authorities have expanded their resources as part of preparations for dealing with tax avoidance.
Although this may mean more stringent standards for investment, the Irish tax authorities are very keen to keep a positive relationship with business. The need for stability and certainty is seen as a key factor for retaining a strong level of investor confidence. It's a balancing act between the international obligations of the Irish government and the need to remain competitive.
As part of the BEPS project, Ireland has set out to adopt several new measures and the Irish government has signed up to the multilateral instrument (MLI) on June 7 2017. The MLI will reinforce Ireland's commitment to BEPS and facilitate the renegotiation of 72 double tax treaties (DTTs) and implement two minimum BEPS standards. These standards relate to the prevention of treaty abuse and dispute resolution through a mutual agreement procedure (MAP).
"We would see BEPS and ATAD as having much more of an impact on Irish tax affairs than Trump's tax plans or even Brexit," said Caroline Devlin, co-chair of Arthur Cox's tax group. "These things will continue into the future for a long time."
Depending on the impact of BEPS and what kind of Brexit deal is eventually reached, even more British companies could move operations to Ireland. However, as part of the international shift seen elsewhere in Europe as a result of BEPS, foreign companies will be expected to bring substance with their investments in Ireland.
"Ireland is keen to address issues of exploitation and it has shown it can act to close those loopholes down," said Jonathan Sheehan, head of the tax group at Walkers Global. "The theme running through the Apple case is that Ireland cares deeply about substance. The likes of Google, Apple and LinkedIn have a significant number of employees here. These are substantive operations."
International Financial Services Centre,
North Wall Quay,
Paul Fahy, Head of Tax
T: +353 1 649 2717
Three time winner of the International Tax Review European Tax Award for Ireland, A&L Goodbody's Tax Group provides Irish taxation advisory and transactional services to many of the world's largest corporates and financial institutions. In recent years, the team has provided tax advice on most of the leading transactions that have been completed in the Irish market.
Ten Earlsfort Terrace
Tel: +353 1 920 1000
Fax: +353 1 920 1020
Caroline Devlin, Co-chair Tax Group
Fintan Clancy, Co-chair Tax Group
Ailish Finnerty, Partner
Aisling Burke, Partner
Baker Tilly Hughes Blake has a large team of tax professionals offering a full suite of tax services from tax compliance to international tax to complex restructuring. The international tax team is led by Donal Leahy who has a number of years' experience assisting foreign multinationals expand into Ireland and also ensuring that corporates achieve optimum Irish tax efficiencies. Working closely with the Baker Tilly International firms and the Global Tax Solutions offering (see www.bakertillygts.com for more details), Baker Tilly Hughes Blake has a commercial, responsive and agile approach to providing international tax solutions that involve many countries requiring a centralised delivery model.
Partner | Head of Tax
Tel: +353 (0)1 669 9999
Partner | Tax
Tel: +353 (0)1 669 9999
22/23 Holles Street
Tel: +353 (0)1 669 9999
Tel: +353 (0)53 92 33333
No. 5 Lapps Quay
Tel: +353 (0)21 494 3987
Deloitte & Touche House
Tel: +353 (0) 1 417 2200
Fax: +353 (0) 1 417 2300
Deloitte is one of the largest providers of tax services on the island of Ireland, with 18 tax partners and nearly 250 dedicated tax professionals in five locations. Deloitte Ireland provides tax consulting and compliance services to a wide range of clients, including multinational corporations, Irish plcs and indigenous Irish companies spanning multiple industries. In addition, we advise high-net-worth individuals and family offices on taxation and succession-planning matters. In addition, in 2016 we were recognized by the prestigious International Tax Review with an award as Transfer Pricing Firm of the Year in Ireland, which is the third time we have won this award.
Deloitte Ireland is part of the global network of Deloitte member firms, which includes more than 30,000 member firm tax partners and professionals worldwide. Services can be provided by using a local approach, a global or regionally coordinated approach or a centralised approach to increase efficiency and control over tax activities. With Deloitte Ireland and the Deloitte network of member firms, clients can gain the benefits of global reach while retaining access to local tax knowledge when and where they need it. This means better relations with revenue authorities, faster responses to regulatory changes, and a tax provider with a deeper understanding of their issues and the environments and industries in which they operate. Our service delivery model is designed to adapt and evolve quickly as companies grow and as priorities shift. This enables clients to remain agile and to respond quickly and efficiently to marketplace changes.
Deloitte Ireland provides the full suite of tax services, including the following:
Head of Tax
Tel: +353 (0) 1 417 2992
Ernst & Young Building
Tel: +353 1 475 0555
Country Tax Leader
Tel: +353 1 221 2478
Global Compliance and Reporting
Tel: +353 1 221 2478
Tel: +353 1 2211514
Tel: +353 1 2212434
Tel: +353 1 221 2413
International Tax Services
Tel: +353 1 221 2457
Life Sciences Tax Services
Tel: +353 1 221 1139
Private Client Services
Tel: +353 61 317 784
R&D Tax Services
Tel: +353 1 221 2638
Tel: +353 1 221 2015
Tel: +353 1 221 2094
Maples and Calder
75 St Stephen's Green
Tel: +353 1 619 2000
Fax: +353 1 619 2001
Maples and Calder is a leading law firm advising on the laws of Ireland, the Cayman Islands and the British Virgin Islands.
Maples and Calder's Tax Group advises international companies, financial institutions, investment firms and significant family offices. Our Group is made up of senior and experienced tax lawyers and prides itself on its technical excellence and transactional capabilities.
We work closely with counsel in the world's leading financial centres and with lawyers across our firm to develop innova- tive solutions for our clients.
We advise investors from around the world on the structuring of their international investments through Irish investment companies and Irish funds. We also advise businesses establishing a presence in Ireland.
Through our affiliate, MaplesFS, a leading provider of fiduciary and fund services, we provide a "one stop" service in establishing and servicing structures for our clients, including the provision of independent directors, Irish tax compliance and FATCA/CRS reporting.
Our Tax Group is described by leading directories as a "partner led service" and "a pragmatic and responsive team that understands the practical, commercial issues".
For a different perspective, please contact:
Head of Tax
+353 1 619 2038
Mason Hayes & Curran
South Bank House, Barrow Street, D4
Tel: +353 1 614 5000 Web: www.mhc.ie
Managing Partner: Declan Black
DD: +353 1 614 5017
Head of Tax: John Gulliver
DD: +353 1 614 5007
Tax Partner: Robert Henson
DD: +353 1 614 2314
Tax Partner: Maura Dineen
DD: +353 1 614 2444
Of Counsel: Niamh Keogh
DD: +353 1 614 5848
Mason Hayes & Curran, one of Ireland's top law firms, offers an internationally experienced tax team of partners and professionals. The tax group provides innovative and leading edge tax services to its multinational corporate client base including Fortune 500 and FTSE 100 quoted companies, financial institutions, and merchant banks.
|Corporate Income Tax||12.5%||A|
|Capital Gains Tax||33%||B|
|Net Operating Losses (years)|
|Interest||20%||D E F|
|Royalties from, for example, patents, know-how||20%||D F G|
A) This rate applies to trading income and to certain dividends received from non-resident companies. A 25% rate applies to certain income and to certain activities.
B) A 40% rate applies to disposals of certain life insurance policies.
C) This withholding tax is imposed on dividends distributed subject to exceptions
D) Applicable to both residents and non-residents.
E) Interest paid by a company in the course of a trade or business to a company resident in another European Union (EU) member state or in a country with which Ireland has entered into a double tax treaty is exempt from withholding tax, subject to conditions. Bank deposit interest is subject to a 41% deposit interest retention tax (DIRT). DIRT exemptions apply to bank interest paid to non-residents and, subject to certain conditions, bank interest paid to Irish resident companies and pension funds.
FIreland implemented the EU Interest and Royalties Directive, effective from January 1 2004.
G) Under Irish domestic law, withholding tax on royalties applies only to certain patent royalties and to other payments regarded as "annual payments" under Irish law. The Irish Revenue has confirmed that withholding tax need not be deducted from royalties paid to non-residents with respect to foreign patents (subject to conditions).
Partner Paul Fahy is the head of tax at A&L Goodbody. The tax group offers the full range of services, such as advice on M&A deals, inversions, capital markets, loan portfolios, foreign direct investment (FDI) and transfer pricing. Another distinguished partner at the firm is James Somerville. Meanwhile Amelia O'Beirne heads the New York office and Gina Conheady oversees the team in San Francisco.
The tax team provides domestic and international clients with advice on corporate restructuring, complex cross-border transactions and multinational tax planning. The firm has a strong and diverse client base, covering such areas as financial services, pharmaceuticals, aviation, real estate, manufacturing and the high-tech sector.
One client said: "As A&L Goodbody's tax department is much smaller than the Big 4 accounting firms, we tend to receive a more personal service and find it beneficial that they have property lawyers available to them."
Fintan Clancy and Caroline Devlin are the co-heads of the tax group at Arthur Cox. Previously, Clancy worked for Skadden, Arps, Slate, Meagher & Flom and Herbert Smith Freehills. The practice consists of five partners and 16 other fee earners. The firm's tax services range includes corporate tax, transactions, stamp duty and VAT.
Recent additions to the tax team include Ciara Fagan and Elaine Mooney. The tax practice at Arthur Cox liaises with the Irish tax authorities on policy and legislation. Key focus areas are M&A, securitisation, intellectual property (IP) rights and on-shoring, private equity, disposals and reorganisations. The firm's client base covers a variety of key industries such as finance, real estate, construction and engineering.
One client said: "I am very happy with the service received from Arthur Cox and would recommend them to other companies."
Partner Alma O'Brien heads the tax practice at Baker Tilly Hughes Blake. She specialises in advising owner-managed and family-owned businesses. O'Brien works closely with tax partner Donal Leahy, who has expertise in tax advice for domestic and international companies expanding their business in Ireland.
Having expanded significantly in recent years, the firm is one of the fastest growing in Ireland. The practice offers a variety of tax services to its clients, which range from SMEs to multinationals and Fortune 500 companies. These services include international and corporate tax, compliance and VAT, cross-border issues and business relocation.
The firm has developed a number of innovative tax products, such as Baker Tilly global tax solutions, through which a group's worldwide tax affairs can be managed by one entity. Partner Chris Danes leads Baker Tilly global tax solutions.
Head of tax Lorraine Griffin oversees the practice at Deloitte Ireland. The firm advises clients on all areas of tax matters, such as corporate tax, FDI, transfer pricing, R&D, dispute resolution, transactions, direct and indirect tax. The practice consists of 19 partners and more than 240 other professionals.
Deloitte's clients operate in a variety of sectors, including life sciences, real estate, financial services, technology, media and telecommunications (TMT). It also serves high-net-worth individuals from some of the wealthiest families in Ireland. Partner Joanne Whelan oversees the private client service, while director Gerard Feeney leads the firm's transfer pricing unit.
The Deloitte tax practice encompasses in-depth corporate knowledge and the skillsets necessary to pursue innovative solutions for client's tax concerns. As part of Deloitte's international strategy, the Irish firm is rolling out automated tools to assist clients in meeting their obligations under new legislation.
Partner David Lawless is the head of tax at Dillon Eustace. He has 30 years of experience in the field and has advised clients on all areas of tax, particularly with regard to investment, transactions, capital markets, real estate and private equity.
Established in 2004, the team at Dillon Eustace comprises tax, legal and accounting professionals, offering a wide range of advice on tax issues. The firm provides a comprehensive range of services to domestic and international clients, especially from the financial services sector. The team's remit covers asset management, investment funds, corporate tax, capital markets, real estate and bank deleveraging.
EY's tax team is overseen by Kevin McLoughlin. He has close to 20 years of experience in the field, including a number of years spent on the Irish tax desk at EY in California. This experience is an advantage given the strong ties between Ireland and the US. McLoughlin has expertise in cross-border planning, inward investment and M&A.
The Irish tax team is composed of three main offices in Dublin, Cork and Waterford. The practice specialises in international tax, indirect tax, human capital, business tax and transfer pricing for such sectors as aviation and life sciences.
Grant Thornton offers a comprehensive range of tax advice in Ireland. A key partner at the firm is Frank Walsh, who joined the tax practice in 1980. Walsh has impressive expertise in foreign direct investment and outbound investments. He advised major companies and banks on restructuring after the 2008 financial crisis.
The Grant Thornton tax practice advises clients on a variety of issues, such as IP rights, intangible assets, R&D tax credits, M&A transactions and tax-efficient structures. The firm draws clients from the financial services sector, and from high-tech and pharmaceutical businesses.
Partner Conor O'Brien is the head of tax and legal services at KPMG in Ireland, with offices in Dublin, Belfast and Galway. He advises a wide range of clients, both domestic and international, with particular expertise in tax treaties, stamp duty, debt and equity. This includes substantial companies in sectors such as technology, manufacturing and banking. The Irish tax group at KPMG provides advice and assistance on all areas of tax, such as risk management, auditing, corporate tax and VAT.
Andrew Quinn is the head of the tax group at Maples and Calder. He has a wealth of knowledge in international tax, especially in relation to banks, investment funds and other financial institutions. The firm offers a comprehensive scope of tax services, including structured finance, reorganisation, FDI, tax controversy and litigation.
Maples and Calder is known for the quality of its service in transactions. The tax group prides itself on technical excellence and innovation in developing new structures and strategies for clients drawn from important sectors of the global economy. This includes investment banking, asset management, aviation, real estate, hedge funds and private equity.
Many of the firm's cases involve transactions across jurisdictions, usually between the US and the EU. The tax group liaises with the Irish government through industry associations, particularly on legislative developments.
With more than 20 years of experience, John Gulliver serves as the head of tax services at Mason Hayes & Curran. He has advised numerous Fortune 500 and FTSE 100 companies on international tax matters. The firm offers a comprehensive service range including transactions, cross-border mergers and post-acquisition restructuring.
Gulliver works alongside fellow partners Robert Henson and Maura Dineen. The two of them have advised multinational companies on a range of corporate tax issues, particularly M&A, IP exploitation, restructuring and inbound investments. The firm's client base spans a varied set of sectors from asset finance to aircraft leasing.
In one case this year, Mason Hayes & Curran advised West Pharmaceutical, one of the world's biggest medical device producers, on a group reorganisations involving an Irish holding company. This deal was valued at $2 billion.
Head of tax Turlough Galvin oversees Matheson's tax practice. He specialises in tax structuring, covering all forms of structured finance, securitisation, derivatives, M&A and stamp duty. Galvin also advises clients on transfer pricing and tax disputes.
With 37 practitioners, Matheson has one of the biggest tax teams in Ireland. It consists of 15 partners and 22 other professionals. The team offers the full range of tax services, including group reorganisations, dispute resolution, litigation, cross-border issues and state aid matters. Held in high esteem by clients and peers, the firm is the first choice for many US and EU multinationals, investment banks and financial institutions.
Given the importance of US investments in Ireland, Matheson has established a US presence with offices in New York and Palo Alto, overseen by tax principal John Ryan, partner Alan Keating and partner Mark O'Sullivan.
Michael Ryan leads the tax group at McCann FitzGerald. He used to be a member of the Irish Tax Institute and now chairs the editorial board of the Irish Tax Review. The firm provides a wide array of tax services, including transactions and dispute resolution. The tax group has strong expertise in the entire spectrum of structured finance.
Other key partners include Eleanor MacDonagh and Alan Heuston. MacDonagh is the head of financial services with expertise in international tax structuring. Heuston has extensive experience in advising clients on the tax aspects of M&A, IP rights, restructuring and reorganisation. The tax team is able to accommodate clients looking to redesign investment platforms along tax efficient lines, restructure M&A transactions and corporate inversions.
Managing partner Feargal O'Rourke heads the tax practice at PwC Ireland. O'Rourke has more than 30 years of experience advising investors, Irish companies and multinational corporations.
The PwC tax team provides clients with a full suite of services covering the financial and real estate sectors, including advice and assistance on international tax, VAT, customs, dispute resolution and controversy.
Jonathan Sheehan is the head of the Walkers tax group. He advises across a wide range of tax areas, such as structured finance, capital markets, private equity and investment funds. The firm has a comprehensive transactional tax practice, which covers such areas as aviation, banking and real estate.
Walkers provides clients with a wide range of tax services and often handles transactions involving multiple jurisdictions, such as Bermuda, the British Virgin Islands, Guernsey, Jersey and the Cayman Islands. These deals sometimes involve funds and real estate portfolios worth more than $1 billion. This requires multiple teams working from offices around the world. Walkers Global has a presence in Ireland, Hong Kong, the UK and Singapore.
Walkers is held in high regard by peers and clients alike. One client said: "Jonathan Sheehan is an impressive tax attorney. Technically very able, but also very practical."
Partner Martin Phelan is head of tax at William Fry, Taxand Ireland. Formerly the president of the Irish Tax Institute, Phelan has more than 30 years of experience practicing tax law. He was at KPMG for 12 years before joining William Fry in 1999. The firm provides clients with a full and integrated range of tax services, such as litigation, transactions, compliance and due diligence.
William Fry continues to expand, with new hires this year including Tina Curran, Anne Harvey and David Barron. Harvey was at PwC for 20 years. The tax practice itself is divided into different teams focusing on key areas, such as FDI, transfer pricing, financial services and secondments. The Irish law firm's clientele includes high-profile businesses from such sectors such as finance, high-tech, retail and telecommunications.