Ireland has long been an attractive location for the establishment of international holding companies. Why? It is a low Corporate Tax environment, has an extensive tax treaty network and a general ability to pay dividends free of withholding taxes.
At FMB, our team has worked closely with overseas clients to set up operations in Ireland, or to establish holding companies. We do our very best to make the process easy – whether you are an established part of Ireland’s business community, or whether this is your first time doing business in Ireland. Ireland is an attractive location to set up a business for many reasons. Firstly, the 12.5% Corporate Tax rate on domestic trading income is hugely significant for our clients. Also:
There is a Capital Gains Tax exemption on the disposal of subsidiaries in Ireland, the EU or treaty countries. That includes countries with which Ireland has signed but not yet ratified a tax treaty. Foreign taxes can be relieved on dividends received by Irish companies. This occurs under unilateral provisions in Irish law, in accordance with the EU Parent Subsidiary Directive and under bilateral treaty provisions. Foreign dividends which have emanated from trading profits are also taxed at the 12.5% trading rate.
This is also the case where the dividends have been paid out of dividends received from lower tier companies engaged in trading activities. In most cases the low tax rate, coupled with the double tax relief, ensures that no further liability to Irish tax arises on the receipt of such dividends. In cases where the foreign tax exceeds the Irish tax on a specific dividend the excess may be offset against Irish tax on the remaining foreign dividends on a ‘like for like’ basis. This on-shore pooling also ensures that unused tax credits may be carried forward indefinitely. There is the potential for intermediate holding companies to migrate from Ireland without incurring a tax charge.
And finally, there are tax-free and withholding tax-free capital distributions available to non-resident individuals on liquidations in most cases. These technicalities may seem dry and unexciting, but added together they’re what makes Ireland a superb base for international holding companies. At FMB, our team has the experience and know-how to bring your company to low-tax Ireland.
To speak to John, you can book a consultation today and find out more on the attractions of investing in Ireland.
Sign up to our newsletters to keep yourself informed and up to date on new developments which may be of relevance to your business
Contact us to receive professional and informed advice on investing in Ireland.
26 April 2024
New home completions down 12% in first quarter of 2024 – CSO
There was a 12.1% fall in the number of new…
26 April 2024
Ireland ranks second in Europe for remote work opportunities
Ireland has one of the highest shares of hybrid and…
26 April 2024
Third month of decline in consumer sentiment – Credit Union index
There was a marginal fall in consumer sentiment for a…
25 April 2024
Banks need to do more for borrowers in early mortgage arrears – Central Bank
A Central Bank review of the supports that are in…
25 April 2024
Over 53,000 businesses still using Revenue’s Tax Debt Warehousing scheme
The outstanding debt owned by businesses that availed of Revenue’s…
25 April 2024
Diversity report shows more women in senior management roles
A survey of businesses that signed up to a pledge…
24 April 2024
Covid supports stabilised labour market but inequality persists – study
Employment and social welfare supports during the Covid pandemic helped…
24 April 2024
European Parliament to vote on money laundering law
New laws to tackle money laundering, terrorist financing and sanctions…
24 April 2024
Consumers want to make ‘green’ choices but cost dominates – survey
Consumers want to make sustainable choices but cost and other…
23 April 2024
Wholesale electricity prices 40% lower in March on last year
New figures from the Central Statistics Office show that wholesale…
Registered to carry on audit work by Chartered Accountants Ireland
© 2024 FMB Advisory Ltd. All Rights Reserved.