The
development of the European single market during the 1980s and 1990s,
together
with a consistently pro-business attitude on the part of the Irish
Government
has seen the emergence of Ireland as one of the fastest-growing
European
states, and the establishment of the International Financial Services
Centre in
Dublin, along with the Shannon Airport tax-free area, has led to the
development of a substantial offshore business sector, made more or
less
redundant in 2003 by Ireland's adoption of a universal 12.5% corporate
tax
rate.
According
to the Finance Dublin Yearbook 2008, total employment in the three core
sectors
of banking, funds and insurance stood at more than 25,000 at end
December 2007,
up by 31% from 19,095 on the same date two years earlier.
Solutions
offered by Irish Incorporations Ltd. are based on matching
client
requirements with different types of company structures and other
measures
designed to maximise wealth.
The
'offshore' environment provided by the International Financial Services
Centre
(IFSC) in Dublin
is attractive to multinationals looking to locate treasury management
and other
corporate financial functions in a fiscally-flexible but sophisticated
environment,
and many such operations have based themselves there.
Application
for a certificate entitling a company to favourable tax treatment is
made to
the Industrial Development Agency (IDA) and the certificate is issued
by the
Minister of Finance.
Among
the
stated activities which the IFSC was set up to encourage and
accommodate are a
number of corporate functions, including the following:
- the
provision of foreign currency services for non-residents;
- the
carrying on of financial services for non-residents including global
money management, dealing and trading in securities denominated in
foreign currencies;
- the
provision for non-residents of services of or facilities for
processing, control, accountancy, communication, clearing, settlement
or information storage in relation to financial activities; and
- the development of or
supply of software for use in the provision of services
or facilities mentioned in the last item.
Since
2003, companies established in the IFSC are supervised by the Irish
Financial
Services Authority.
It
is
not necessary to establish a separate subsidiary in order to carry out
corporate financial functions in the IFSC; there are agency companies
and
'shared service centres' which provide certificated services to
overseas client
corporations for a number of the more usual corporate functions.
Ireland
is a convenient
location in which to base companies for the collection of royalties or
other
payments resulting from the exploitation of intellectual property
rights.
The
activities
eligible for Royalty treatment are: Activities relating to the
acquisition, disposal, license, sub-license and exploitation generally
of
intellectual property rights.
Acquisition
by the Irish company of the rights in the first place can usually be
carried
out without a stamp duty or transfer charge; and there are no thin
capitalisation rules, so that capital duties will be minimal.
Ireland's
extensive network of
Double Tax Treaties will ensure that incoming revenues are normally
free of
withholding taxes. In some cases, the tax treaty might have excluded
payments
destined for companies which don't pay 'normal' taxes; this problem has
perhaps
disappeared now that the 12.5% rate is in force, because it is the
EU-accepted
'normal' rate.
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