International tax

In HLB McKeogh Gallagher Ryan all our senior tax experts have a “big firm” background and worked on international tax assignments, particularly in the property and hospitality sectors, devising cross-border tax structures to effectively offset trading and transaction liabilities. Our membership of HLB International gives us direct access to an international network of tax professionals and we can provide international tax compliance and advisory services to our clients.

IRELAND AS AN ATTRACTIVE LOCATION

We assist foreign companies and business owners set up in Ireland.  There are many factors contributing to Ireland’s attractiveness including–

  • Low corporate tax rates:
    • 12.5% for active business profits
    • 25% for passive type income
  •  An ever expanding network of double tax agreements which facilitates:
    • Double taxation relief on branch profits
    • Beneficial tax treatments as regards application of withholding taxes to royalties, interest and dividend payments under terms of double tax agreements / domestic tax legislation [Can be relevant when considering repatriation of profits]
  • Capital gains tax exemption on disposal of qualifying shareholdings which allows for:
    • Tax efficient holding company regimes
    • Sale of subsidiary trading companies at no tax cost
  • Tax relief / exemption for certain start-up companies
  • Tax credit for R&D expenditure:
    • Additional tax credits as a percentage of R&D expenditure (this is additional to tax deductibility of R&D cost under normal accounting rules)
    • Tax credit can apply to both revenue and capital-related expenditure
  • Tax incentives for acquiring intangible assets (e.g. intellectual property):
    • Tax relief on capital costs of acquiring such assets
    • No property transfer taxes (i.e. stamp duty) on acquisition cost
  • Dividends – foreign tax credit system:
    • Excess foreign tax credits can be pooled and carried forward
    • Company can elect to pay tax at 12.5% rate (as opposed to 25% rate) on certain foreign dividend income
    • Can lead to little or no corporation tax liability in Ireland on such income
    • Favourable dividend withholding system
  • No capital duty
  • No Controlled Foreign Company (“CFC”) or thin capitalisation rules

OUR SERVICES

The international tax services we provide include:

  • Constructing tax-efficient cross-border structures
  • Cross-border VAT issues
  • Tax services for ex pats – for both incoming and outgoing employees
  • International tax planning services (tax, legislative and compliance)
  • Tax advice to Irish businesses expanding overseas
  • Tax advice to foreign companies entering the Irish market:
    • Incorporating or winding up of Irish companies
    • Acquisition and disposal of Irish companies, whether they are stand alone or part of a group of companies
  • Tax efficient structures for Intellectual Property (IP)
  • The efficient use of foreign company losses and profit repatriation
  • Location of assets
  • Audit of Irish companies within multinational groups