Why Choose Ireland for Holding Companies?

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Holding Companies – Why chose Ireland for Holding Companies?Ireland is an attractive place to set up a Holding Company for many reasons as outlined below.

The main advantage of setting up a Holding Company in Ireland is the introduction of the new participation exemption which exempts qualifying distributions received by a holding company from its subsidiary from Corporation Tax in Ireland. Prior to this, the tax rate of dividends received from foreign subsidiaries was reduced to 12.5% in certain cases so the introduction of the new participation exemption is welcomed.

We have outlined the main benefits of setting up a Holding Company in Ireland below:

  • Dividend income between two Irish companies is exempt from tax in Ireland.
  • As mentioned above, there is a new participation exemption for foreign dividends which exempts qualifying distribution from corporation tax. The key conditions of this participation exemption are as follows:
    • Resident in and EEA state or a country which has a DTA with Ireland.
    • The recipient of the dividend must hold at least 5% of the shareholding of the paying company for an uninterrupted period of 12 months.
    • It must not be tax deductible in any other jurisdiction.
    • Made out of profits of the paying company.
    • The company must opt in for this exemption on a yearly basis.
  • There is also a participation exemption on the disposal of shares in a trading subsidiary company on shareholdings of at least 5 years that have been held for at least 12 months.
  • Dividend Withholding Tax (DWT) exemptions:
    • Group exemption – exemption from DWT if the Holding Company is a 51% parent of the paying company.
    • EU Parent Subsidiary – Provides an exemption from DWT on the dividends between parents and subsidiaries. The parent company must own 5% of the shares during an interrupted period of 2 years.
    • DTA DWT exemptions.
  • The tax rate for trading companies in Ireland is 12.5% and for passive income is 25%.
  • Expenses of managing a holding company are generally tax deductible in Ireland.
  • English speaking country.
  • Part of the EU.

CFC Rules Ireland

CFC rules prevent the artificial diversion of profits from controlling companies to CFCs (offshore entities in low-tax or no-tax jurisdictions). The Irish regime can be summarised as:

  • The charge applies to undistributed income of a CFC arising from non-genuine arrangements put in place essentially to avoid tax.
  • Such undistributed income is attributed for taxation purposes to the Irish controlling company, or connected company, where that company has been carrying out significant people functions (“SPF”) in Ireland.
  • There are exemptions for CFCs with low profits or low profit margin or where the CFC pays a comparatively higher amount of tax in its territory that it would have paid in Ireland.
  • The CFC rules will not apply where the arrangements under which SPFs are performed have been entered into on an arm’s length basis or are subject to transfer pricing rules.
  • Unless an exemption applies, undistributed income, with an Irish nexus by reference to Irish SPFs, which has been artificially diverted from Ireland, will fall to be taxed in Ireland.
  • To prevent double taxation, a credit will be available against the CFC charge for foreign tax paid on the same income.

We can assist on all aspects of setting up a Holding Company in Ireland whether it is incorporating the company, tax compliance and advice, or the preparation and audit of financial statements. If you wish to discuss, please contact us.

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DFK International Ranked 6th Largest Association in the World

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DFK International has been ranked as the 6th largest association in the world in the International Accounting Bulletin’s (IAB’s) annual 2022 World Survey Report.

Crowleys DFK has been a proud member of DFK International for twenty-nine years.

The report is based on collective fee income, with DFK International members firms achieving a turnover of $1.532 billion.

DFK has sat in seventh place for 10 years but has moved up the list after achieving a growth rate of 3% compared to the previous year.

The association now has 230 member firms, 1,413 partners, 13,919 staff members and 455 offices in 94 countries.

Martin Sharp, executive director of DFK International, said:

“We are very proud to be among the leading associations worldwide.

Moving up to sixth place demonstrates that despite the pandemic, DFK remains one of the strongest associations in the world and our member firms have continued to grow, which is a fantastic achievement.

We have seen growth across all services lines, particularly in North America, which shows that our members have continued to provide outstanding support to their clients in a challenging environment and in-turn have expanded their practices.

We now look forward to another successful year as we continue to do business and share knowledge and best practice to achieve further growth.”

Being a part of an association with a strong global presence has greatly widened Crowleys DFK’s intellectual resources, allowing us to offer local advice supported by a broader knowledge of international financial reporting.

This breadth of knowledge is a critical resource for our clients, which include leading firms in industries such as information and communications technology, e-commerce, life sciences, manufacturing and consumer products.

These clients find that our expert team provides fundamental advice on structuring their Irish operations, on securing Government funding, and dealing with tax and legal obligations.

As Ireland continues to be a vital hub for international business, our understanding of the challenges faced by companies moving into Ireland will continue to be a critical resource.

Eddie Murphy, Head of Tax and FDI Services at Crowleys DFK, said:

“At Crowleys DFK, we understand the challenges faced by our SME and owner-managed business clients. We are proud of the reputation and long-term relationships we have built with them over the years.

Whether it’s getting advice on taking on two employees in Germany, accessing capital markets in London or New York or helping technology companies expand into San Francisco, we connect our clients with trusted professionals throughout the world.

In many cases our clients prefer to deal with us and in these instances, we instruct the other DFK firms. This means clients can concentrate on their business and don’t need to spend time developing new relationships abroad.”

To learn more about DFK International visit www.dfk.com.

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Crowleys DFK Celebrates DFK’s 60th Anniversary

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DFK's 60th Anniversary

Crowleys DFK is celebrating global independent accountancy association DFK’s 60th anniversary. We are proud to have been members for the past 29 years.

Reflecting on the 60th milestone, Martin Sharp, executive director of DFK International, said:

“In 1962 the founders of DFK International envisaged setting up an association of independent firms that could support their clients to do business internationally and provide an alternative to the big networks which were being set-up.

Although DFK has grown considerably and the international business landscape has changed, the principles and ethos on which DFK was established still remain.

Beyond this, DFK provides a forum to share knowledge and best practice between like-minded individuals who are keen to support their clients and help fellow member firms.

We have a strong family atmosphere which has grown over the years to give member firms the opportunity to build relationships with people from different countries and different cultures.

This year we celebrate this success and look forward to continuing to build these relationships in the years to come.”

James O’Connor, Managing Partner at Crowleys DFK commented:

“There is no doubt that joining DFK in 1993 has been a significant catalyst in the success and growth of our firm. Since then, we have grown to become a 10 Partner and 115 staff practice and one of the leading independent practices in Ireland.

There is great comfort in being able to connect our clients with trusted friends all around the world when they need help and advice abroad.”

The association provides us with a platform to share knowledge, ideas and best practice as well as information about the latest technology to ensure we remain at the forefront of the sector.

It is also a pioneer in training and development, creating programmes to specifically develop young professionals in the industry as they progress in their careers.

DFK International has 229 member firms which have a combined total of 441 offices across 93 countries.

The association strives for equality, diversity and inclusion, promoting a culture that celebrates difference, challenges prejudice and ensures fairness.

We are proud to have been part of such a magnificent organisation for such a long time and look forward to continuing to be part of the DFK family.

DFK International Conference 2019 in Singapore

Eddie Murphy & James O’Connor DFK International Conference 2019, Singapore

Happy 60th Birthday DFK!

To learn more about DFK International visit www.dfk.com.

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Crowleys DFK Support Cork SMEs’ Global Success

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Edward Murphy, Head of Tax, was featured in Cork Chamber’s 200th anniversary magazine. He discusses Cork, the local Cork SME sector and it’s success on the domestic and global stage.

You can read the full interview below.

Q:   What’s it like to do business in Ireland’s fastest growing city region?

A:   It’s hard not to be excited by the hive of activity in Cork in recent years – from the myriad of new developments, a growing workforce and a thriving third-level education sector to the region’s continued success in attracting high-value overseas investment. However, it’s the global success of our indigenous Cork SME sector that is, perhaps the most exciting.

Q:   Why have indigenous Cork SMEs been so successful locally and globally?

A:   While Cork has a well-earned reputation in attracting and retaining foreign direct investment, the support it offers homegrown entrepreneurs and SMEs is second to none. Innovation and the ambition to think globally is nurtured through an excellent support ecosystem of start-up incubators, accelerator programmes and research, development and innovation hubs; backed by local business organisations, third-level institutions, and public and private investors.

Q:   What are the key challenges facing SMEs looking to expand overseas?

A:   The continued uncertainty surrounding Brexit is currently the biggest challenge facing SMEs that trade with the UK. However, a constant challenge relevant to all markets is access to local, trusted and reliable professional connections and advice overseas. This is a key step in any global expansion strategy and is often a major stumbling block for many businesses. Understanding how to do business in a new jurisdiction can be time consuming and expensive when you don’t have a local relationship or know where to go to get the proper advice.

Q:   Can you describe how Crowleys DFK can help SMEs with their international growth strategies?

A:   At Crowleys DFK, we understand the challenges faced by our SME and owner-managed business clients. We are proud of the reputation and long-term relationships we have built with them over the years. They represent a diverse range of today’s most innovative and high-performing industries and sectors, including information and communications technology, life sciences, manufacturing and consumer products.

We have been a member of DFK International since 1993. This worldwide association of independent accounting, tax and business advisory firms has over 220 member firms covering 92 countries. We have a long history of working with other DFK Firms. It’s through these strong relationships that we can deliver a complete international service to clients.

Whether it’s getting advice on taking on two employees in Germany, accessing capital markets in London or New York or helping technology companies expand into San Francisco, we connect our clients with trusted professionals throughout the world. In many cases our clients prefer to deal with us and in these instances, we instruct the other DFK firms. This means clients can concentrate on their business and don’t need to spend time developing new relationships abroad.

We have all the right connections to help businesses achieve their ambitions – locally and globally.

Contact us today for expert advice on growing your SME.

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Crowleys DFK launches Overview Video on Foreign Direct Investment Service Offering

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Crowleys DFK is delighted to launch an overview video of the Firm’s Foreign Direct Investment service offering.

Edward Murphy, Partner and Head of Foreign Direct Investment and Siobhán O’Hea, Partner, Tax Services provide an insight into how Crowleys DFK can help foreign owned companies to set up operations in Ireland.

For more information on our Foreign Direct Investment service offering, please contact Edward Murphy.

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Benefits of locating your business in Ireland

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Ireland enjoys an enviable reputation as a business-friendly location and it’s not just global giants who reap the benefits, says Edward Murphy, Partner and Head of Tax Services.

Ireland is home to many of the world’s most successful companies. Sixteen of the top twenty global technology firms are located here as are twenty-four of the twenty-five top biotech and pharma companies.

However, it is not just global giants that reap the benefits of doing business in Ireland. Many smaller companies also take advantage of the pro-business culture and ease of access to EU markets.

In the software sector alone, more than 900 multinational and indigenous firms employ 24,000 people generating €16 billion of exports annually, according to IDA Ireland, the state agency responsible for promoting foreign direct investment.

Ireland’s Foreign Direct Investment Success

One reason for Ireland’s foreign direct investment (FDI) success is the favourable tax regime. There are double tax treaty agreements in place with 72 other countries and the 12.5 percent corporate tax rate is one of the lowest in the EU.

Other advantages include an attractive holding company regime and tax incentives for certain types of investment. For example, Irish-resident companies carrying out qualifying research and development activity can avail of a ‘Knowledge Development Box’ where eligible profits are taxed at a rate of just 6.25 percent.

Tax not the only reason to locate in Ireland

While tax is undoubtedly an important consideration, it is not the only reason foreign businesses choose to locate in Ireland. Other influences include:

  • Ease of doing business.
  • Supportive state agencies.
  • Political stability.
  • EU membership and proximity to EU markets.
  • Strong legal framework for the development, exploitation and protection of intellectual property rights.
  • English-speaking population (When the UK leaves the EU, Ireland will be the only English-speaking EU member state).
  • Strong talent pipeline with around 30 percent of Irish third level students enrolled in science, technology, engineering and maths (STEM).
  • Collaborative ecosystem where industry and academics work together to the benefit of society and the economy.
  • Growing economy. GDP growth of 4.4 percent is forecast for 2018 and 3.9 percent for
US and Canadian Companies in Ireland

Around 700 US companies are located in Ireland, employing more than 150,000 people.  Anecdotally, US technology companies report that they can hire two engineers in Ireland for the price of one in Silicon Valley, with higher multiples for some engineering specialties.

Notwithstanding the Trump administration’s recent tax reform package which will see US corporation tax rates fall from 35 percent to 20 percent, Ireland’s corporate tax rate is still only around half the US rate when federal taxes are taken into account.

Canadian interest in Ireland is also growing. The EU-Canada trade deal which provisionally came into force in September 2017 will create further opportunities for Canadian businesses seeking to set up in Ireland.

Conclusion

At a time of global economic and political uncertainty, Ireland offers a stable, pro-business environment and is an excellent location from which companies seeking to establish a base in the EU can develop and expand their businesses.

Crowleys DFK assists many foreign owned companies to set up operations in Ireland. For more information and to discuss your specific requirements, please get in touch.

Talk to Us

What Our Clients Say

Edward Murphy
Partner and Head of Tax Services
edward.murphy@crowleysdfk..ie

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