With its highly educated English-speaking workforce and appealing tax environment, Ireland has long been an attractive location for international companies. Roberts Nathan offers foreign-based companies and individuals the opportunity to base some or all of their international operations in Ireland.
Our accountants and advisers can assist you in the process of making Ireland your international base in various ways. The following is an outline of some of the services offered to our international clients:
- Set-up of Irish Holding and Subsidiary Companies.
- Maintenance of all statutory and taxation obligations for such companies.
- Provision of methods of repatriation of profits.
- Provision of Irish directors.
- Provision of Irish registered office.
- Provision of serviced office facility in Ireland.
For further information on our services to international clients, please see below.
Why Invest in Ireland?
Ireland has fast become the destination of choice for some of the world’s leading multinational companies.
The country ranks first in the 2013 Forbes List of Best Countries for Business.
A combination of a favourable taxation infrastructure, EU membership and skilled workforce are but some of the factors which have attracted companies such as Google, Pfizers and Facebook to Ireland’s shores.
While many of these multinationals have set up specific function companies – Intellectual Property or Research & Development holding companies, for instance – others have chosen to locate their trading activities in Ireland as their European headquarters. Ireland is an ideal location from which multinationals may optimise financial and operational performance.
Despite the global economic crisis over recent years, Ireland has continued to attract foreign investment with the continued assistance of the Industrial Development Agency (IDA) of Ireland.
A leading US investor, Wilbur Ross told a gathering of Irish business and cultural leaders in New York that: ‘Ireland is the poster challenge for reform. I award the State 10 out of 10 when asked to grade it as a place to do business. The Irish have come through economic adversity with grit, determination and sacrifice.’
A combination of some or all of the following factors have attracted almost 1,000 multinationals to Ireland, a testament to their confidence in Irelands future.
- Start up grants offered by the Industrial Development Agency (IDA)
- Standard corporation tax rate of 12.5%
- Tax credits on Research & Development expenditure
- Tax relief on the acquisition and development of Intellectual Property
- Double taxation agreements with over 70 countries
- EU and OECD membership
- Skilled and well educated workforce
- Fast and affordable incorporation process
- Only English speaking country in the euro-zone, apart from Malta
- Common law jurisdiction
–Andersen Global Announces Collaboration with Irish Tax Firm, Roberts Nathan
San Francisco, CA – Andersen Global is now collaborating with Roberts Nathan, an Irish tax firm with locations in Dublin and Cork. The establishment of a Collaboration Agreement betweenRoberts Nathan and Andersen Global extends the growing Andersen presence in the European Union, and is an initial step toward becoming a member firm of Andersen Global.
“The Andersen spirit—including an unwavering commitment to client service—is embodied by Roberts Nathan,” said Mark Vorsatz, CEO of Andersen Tax. “This collaboration benefits our clients around the world, as well as our growing firm.”
“Andersen Tax’s unparalleled team and world-class service are an excellent match for our clients-first culture and values,” said Vivian Nathan, Managing Partner at Roberts Nathan. “This growing relationship gives us the ability to leverage our combined talents and resources—a win-win for our clients and our firm.”
Roberts Nathan provides tax planning, compliance and advisory services to businesses and business owners with a focus on businesses establishing operations in Ireland. They will be collaborating with Andersen Global member firms throughout the world to provide best-in-class service to clients. With the inclusion of Roberts Nathan, Andersen Global now has a presence in 51 locations worldwide.
The firm has become the exclusive Irish member of EuraAudit International, an international group of progressive auditors, taxation and business advisors.
EuraAudit International is an international group with over 150 well established independent accountancy firm members across Europe, USA and Asia.
This organisation, EuraAudit International offers multidisciplinary skills by the co-ordination of associated key specialists. The highly qualified and experienced professional teams derived from member firms carry out various assignments to the highest professional and business standards. The efficiency of the service provided by this group is focused on one objective, that being the optimisation of our clients businesses.
We have no doubt that this membership will allow us to further develop the international aspect of our business and we look forward to continued integration and growth with other member firms.
-Transnational Taxation Network
TTN is a multi-disciplinary association of tax, accounting and trust practitioners who have practical interest in international tax on a corporate and personal basis.
The objects of the group are to provide information and contacts to colleagues in various international jurisdictions.
The group meets at different international locations three times a year. These meetings provide opportunities for the members to discuss matters of international tax on an informal basis. The group provides its members with strong educational support by means of the internet and newsletters.
This group provides an infrastructure whereby members of the group can meet, discuss and clarify matters of an international nature.
-International Tax Planning Association
ITPAs are a multi-disciplined association of over 1000 bankers, trust officers, finance directors, accountants, lawyers and others with a practical interest in the tax aspects of cross-frontier transactions.
The object of the Association is to disseminate and exchange information regarding international tax planning. This is completed in three ways – through ITPA meetings, through ITPA publications and via the internet.
Roberts Nathan is located in the IFSC in Dublin. In 2012, the IFSC celebrated its 25th year as one of the world’s leading financial services centres. The importance of the International Financial Services Centre to the Irish economy is indisputable. It has become one of the leading hedge fund service centres in Europe, and many of the world’s most important financial institutions have a presence here. They employ an estimated 35,500+ people and pay about €1 billion in corporate taxes each year, with a further €1 billion going to the exchequer in payroll taxes.
Dublin’s IFSC, which was set up by the Irish Government with EU approval in 1987, is globally recognised as a leading location for a range of internationally trading financial services, including banking, asset financing, fund management, corporate treasury management, investment management, custody and administration and specialised insurance operations.
More than 500 operations were approved to trade in under the IFSC programme. The centre is host to half of the world’s top 50 banks and to half of the top 20 insurance companies. Merrill Lynch, Sumitomo Bank, ABN Amro, Citibank, AIG, JP Morgan (Chase), Commerzbank,BNP Paribas and EMRO are just some of the big-name operations that have chosen to locate in the area. A sophisticated support network, including shared services centres, software development, and legal and accountancy companies, has also developed around the IFSC.
The initial designated site of the IFSC was 11 hectares of land in the Custom House Docks area of the Dublin’s City Centre. This area was one of the largest blocks of prime urban land in the city to be designated for redevelopment. The Custom House Docks Development Authority was established to redevelop the area. Construction started in late 1988 and the first building, the Western Block, was completed and occupied by Allied Irish Banks in 1990.
In May 1997, the Custom House Docks Development was dissolved. At this stage, the IFSC had 114,000 sq m of office accommodation, as well as 333 apartments, a hotel, multi-storey car park and retail space, including a pub, restaurants and the Dublin Exchange Facility. This area is now known as IFSC I.
The Dublin Docklands Development Authority was established in 1997. Its main functions are to continue to develop the original Custom House Docks Area (IFSC I); to develop IFSC II, and to facilitate the development of the Docklands North Lotts area.
A further 4.8 hectares of land has been redeveloped to provide IFSC II, which includes 70,000 sq m of new office space. The overall area is now 15.8 hectares and accommodates over 184,000 sq m of office space, as well as two hotels, two bars and restaurants, a large residential development, retail, a crèche and the €100m National College of Ireland campus, which was officially opened in April 2003.
With effect from 1 January 2010, the remittance basis of taxation relating to foreign income will now only apply to individuals who are not domiciled in Ireland.
This amendment will affect Irish citizens taking up residency in Ireland after a period of time abroad.
Prior to this proposed amendment, Irish individuals who were not ordinarily resident (i.e not tax resident for three consecutive years in Ireland) were only taxable on Irish source income and foreign income to the extent it was remitted during the first three years of their residency.
These individuals will now be taxed on their worldwide income from the first year they become Irish tax resident.
At Roberts Nathan, we have a team of experts in assessing your tax status with regards to:
- Ordinary Resident
Holding Companies in Ireland
Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty network (70 signed, with 68 in effect), lack of CFC & thin capitalisation rules and the general ability to pay dividends free of withholding tax. The ability of US companies migrating to Ireland to continue to use US GAAP, the broadening of the application of the 12.5% rate to foreign dividends received from companies based in non EU/Double Tax Treaty Countries and the simplification of the administrative requirements which must be satisfied in order for an Irish company to pay a dividend to a non-resident company free of withholding tax can be seen as continuing evidence of the Irish Government’s commitment to attracting holding companies to Ireland.
It is for some or all of the above reasons that many of the world’s leading multinational companies have, and continue to, establish holding companies in Ireland.
The Irish tax issues associated with establishing an Irish holding company are reviewed below under the following headings:
- establishment of an Irish holding company;
- taxation of Irish holding companies;
- disposal of shares in an Irish holding company;
- ceasing operations in Ireland; and/li>
- tax treaty network.