Advising UK Data Centre Supplier on Irish Tax Compliance Obligations
The client is a large UK-based supplier of Data Centre and Financial sector critical power solutions.
The client was referred to us by their specialist VAT advisors in UK. They had been engaged to design, manufacture, deliver and install the UPS system at a data centre in Ireland. While the client was to engage Irish-subcontractors for the installation they also intended sending employees from the UK to carry out testing and commissioning.
We were asked to advise the client on any Irish tax compliance obligations arising for the client.
- Reviewing the contract and advising on corporation tax and relevant contracts tax (RCT) registrations in Ireland
- By establishing the length of time the UK-based employees would be on-site in Ireland over the course of the project and then advising the client on its payroll obligations
- Liaising with the client’s internal HR/payroll department and external UK accountants to provide clear advices on what tax exemptions might be available and what certificates of coverage were necessary
- Registering the client for the relevant taxes and filed all Irish tax compliance returns (corporate tax, payroll, relevant contracts tax and VAT) with Irish Revenue
- Reviewing initial invoices issued/received by the client to ensure they were compliant and that the correct rate of VAT and RCT had been applied
- Assisting the client with getting Personal Public Services (PPS) numbers for the relevant employees
- Liaising with Irish Revenue to reduce the rate of RCT on payments to the client to 0%
From the outset of the project, the client was clear on its tax compliance obligations in Ireland and was able to structure employees days on-site in Ireland to minimise its Irish payroll obligations.
Tax Advice on Executive Returning to Ireland
An Irish executive who has been living and working abroad with his family for the past number of years.
The client and his family were returning to Ireland indefinitely. He has various sources of income, cheap such as foreign employment income (including share options) and a significant investment portfolio.
The client required advice on:
- Minimising his exposure to Irish taxes on his return to Ireland.
- How his various sources of income would be taxed upon returning to Ireland.
- Acquiring an investment property in Ireland, help as tax efficiently as possible.
We performed an initial review of the client’s sources of income and identified tax reliefs that may be available.
Following this, we structured the client’s move back to Ireland in a tax efficient way:
- Recommended solicitors to advise and handle the purchase of property.
- Assisted in claiming a split year residence relief on foreign employment income earned during the tax year. This ensured the foreign employment income was not subject to Irish income tax.
- Advised the client on tax treatment of share options from foreign employment exercised, when the client is a tax resident in Ireland.
- Advised on capital gains tax on the sale of share options if shares are sold at the date of exercise or at a future date.
- Advised on the correct tax treatment of funds held by the client in offshore accounts and on any other investments.
- Assisted in a successful application for income tax registration with the Revenue Commissioners.
We provided ongoing support in the form of tax compliance and various tax matters arising, as requested by the client.