INVESTING IN IRELAND THE BENEFITS FOR INTERNATIONAL COMPANIES

Transcription

1 INVESTING IN IRELAND THE BENEFITS FOR INTERNATIONAL COMPANIES Over 1,000 iteratioal compaies have chose Irelad as a place to do busiess. Matheso Ormsby Pretice is the law firm of choice for iteratioal compaies ad fiacial istitutios doig busiess i ad through Irelad. Read o to discover the beefits that Irelad ca provide to your busiess. DUBLIN LONDON NEW YORK PALO ALTO

2 INVESTING IN IRELAND Over 1,000 iteratioal compaies have operatios i Irelad. These compaies are ivolved i a wide rage of activities ad sectors icludig techology, pharmaceuticals, bioscieces, fiacial services ad maufacturig. The attractio of Irelad as a ivestmet locatio ca be attributed to the positive approach of successive Irish Govermets to the promotio of iward ivestmet, its membership of the Europea Uio (EU), a very favourable corporate tax regime ad a skilled ad flexible labour pool. #1 For ivestmet icetives #1 For CORPORATE TAXES #1 For availability of skilled labour #1 For attitudes TO globalisatio * Source: IMD World Competitiveess Yearbook 2011 ad 2012

3 WHY IRELAND? Irelad is 1st i the world for the availability of skilled labour 1st for flexibility ad adaptability of workforce 1st for ivestmet icetives 1st for attitudes towards globalisatio 2d for busiess legislatio for foreig ivestors 2d for large corporatios that are efficiet by iteratioal stadards 2rd for adaptability of compaies 4th for corporate taxes 4th for exports of commercial services Source: IMD World Competitiveess Yearbook 2012 A Pro-Busiess Eviromet Favourable tax regime Flexible busiess ad compay law framework Commo law jurisdictio Eglish speakig Member state of the EU ad withi the Eurozoe Readily available physical ad people ifrastructure Highly developed regulatory ad ecoomic ifrastructure

4 Irelad s uique sellig propositio Taxatio Irelad takes a holistic approach to its tax offerig. The corporate tax rate of 12.5% is just oe igrediet of a competitive tax ifrastructure. Double taxatio treaties, trasfer pricig rules ad sector specific iitiatives are other attractios. ACCESS The prime motivatio for ivestig i Irelad is access to ew markets. Irelad is viewed as a gateway to the EU iteral market. Talet Access to a highly skilled workforce. A base of skilled labour from across the EU (due to ope labour markets). Irelad s workforce see as beig reliable ad able to hadle complexity. Stability Legal ad fiscal stability. Commo law jurisdictio with a legal system broadly similar to that of the US ad UK. A stable regulatory eviromet. Certaity ad clarity of treatmet are key attractios for FDI. *Source: Ivestig i Irelad: A Survey of Foreig Direct Ivestors - report published March 2012, authored by the Ecoomist Itelligece Uit ad commissioed by Matheso Ormsby Pretice

5 Irelad s Tax Beefits 12.5% corporate tax rate The primary beefit, from a tax perspective, of doig busiess i Irelad is Irelad s stadard corporatio tax rate of 12.5%. The 12.5% rate applies to active profits ad is ot depedet o egotiatig or securig icetives, ruligs or other tax holidays. The Irish Govermet has repeatedly reaffirmed its commitmet to the 12.5% rate. There is a willigess to further ehace the Irish tax system to attract further iward ivestmet. IP holdig REGIME There is a relief for the acquisitio of itellectual property ad other itagibles. This allows capital expediture o itagibles to be amortised or depreciated agaist taxable icome derived from such itagibles. Holdig compay STRUCTURE Irelad offers a attractive tax regime for holdig compaies. The two mai features of this regime are; a substatial shareholders exemptio from Irish tax o the sale of subsidiaries, ad; a advatageous treatmet of foreig divided icome. RESEARCH ad DEVELOPMENT A refudable corporatio tax credit of 25% for icremetal qualifyig R&D expediture is available i Irelad. This tax credit is available i respect of qualifyig R&D expediture udertake withi the EEA. This R&D tax credit is i additio to the existig deductio ad capital allowaces that may be available for R&D expediture. 40% of c-suite executives rak Irelad s R&D tax credits system as more competitive tha other locatios (Ecoomist Itelligece Uit).

6 Irelad s tax beefits % 45 Compariso of corporate tax rates Irelad Sigapore Switzerlad Chia Netherlads UK Luxembourg Germay Idia Brazil Frace USA Japa 0 Key tax beefits of locatig i Irelad iclude: Ivestors beefit from: a extesive ad expadig double tax treaty etwork o cotrolled foreig corporatio rules a comprehesive uilateral foreig tax credit system a exemptio from capital gais tax i respect of the disposal of shareholdigs i qualifyig compaies a refudable tax credit of 25% for icremetal research ad developmet expediture a corporate tax relief for the acquisitio cost of IP ad other itagibles o withholdig tax o iterest paymets to EU / Treaty Coutries o thi capitalisatio rules o capital gais tax exit charge to EU / Treaty Coutries o withholdig tax o royalties to EU / Treaty Coutries, ad i certai cases to o-eu / o-treaty Coutries o compaies registratio taxes (capital duty) wide exemptios from withholdig tax o divided paymets o custom duties o Irish goods o their importatio ito other parts of the EU

7 A PRO-BUSINESS ENVIRONMENT Regulatio - Irelad has the regulatory, ecoomic ad people ifrastructure of a highly- developed OECD jurisdictio. Ease of establishig a busiess - It is possible to icorporate a compay withi 5 workig days. Private limited compaies - The 2 mai types of compay i Irelad are private compaies ad public compaies. The vast majority of compaies registered i Irelad are private compaies limited by shares ad are by far the most popular form of busiess etity for iward ivestmet projects. Patet protectio regime - Patet protectio i Irelad will (a) i the case of a fullterm patet, last for a period of 20 years from the date of filig, ad (b) i the case of a short-term patet, last for a period of 10 years from the date of filig, subject to the paymet of reewal fees. Access to skills - both idigeous ad iteratioal via ope labour markets, is a key advatage for busiesses i Irelad. There are also tax breaks for multiatioals to facilitate the relocatio of seior executives to Irelad [Special Assigee Relief Programme (SARP)] Price trasparecy - Irelad is a member of the Europea Moetary Uio, which eables price trasparecy ad reduces the risks of exchage rate fluctuatios i trasactios with other eurozoe customers. Stability - Irelad s legal ad fiscal stability is recogised by ivestors as a key competitive advatage Grat aid ad fiscal icetives - available for iward ivestmet projects, for employmet, capital, research ad developmet ad iovatio purposes Irelad is raked #1 for attitudes to globalisatio (IMD) #1 i Europe as a place to do busiess (Forbes)

8 A track record of success what global ivestors say about Irelad Of the world s TOP 10 pharma compaies ARE IN Irelad Pharmaceutical compaies that have chose Irelad: Abbott Astellas GlaxoSmithKlie Johso & Johso Les Laboratoires Servier Novartis Roche Irelad has established a solid track record as the ideal locatio for may of the world s leadig pharmaceutical busiesses. We see our Dubli base as importat to the evolutio of our busiess, both i our Europea markets ad globally. richard pops, ceo, alkermes plc Because of its busiess-friedly eviromet, strog ifrastructure ad excellet talet pool, Irelad is a ideal locatio for our ew maufacturig facility ad etry ito the Europea market. doald brow, coo, sagart The reaso that Pfizer has expaded i Irelad so extesively is the coutry s prove ability to deliver. The people are reliable ad ca hadle complexity. paul duffy, vice presidet, pfizer

9 A track record of success what global ivestors say about Irelad Of the world s TOP 10 techology compaies ARE IN Irelad Techology compaies that have chose Irelad: Apple EMC Facebook Google Hewlett-Packard LikedI Microsoft Oracle SAP Twitter Irelad is icreasigly oe of the world s cetres of taleted people with iteratioal laguage skills ad experiece i workig for fast-growig iteret compaies. This makes it the ideal place from which to support our cotiuig growth i Europe ad further abroad. coie gibey, iteratioal huma resources director, likedi The skilled talet pool available to us i Irelad has helped us match the growig eeds of our users ad advertisers across the EMEA regio. Dubli is rapidly becomig the multiligual iteret capital of Europe. david marti, director, geo operatios, google europe colm log, director, olie operatios, facebook

10 A track record of success what global ivestors say about Irelad Over half of the world s 50% of the baks ad TOP 20 isurace compaies have operatios i Irelad Fiacial services compaies that have chose Irelad: BNP Paribas Deutsche Bak Goldma Sachs HSBC Rabobak Royal Bak of Scotlad Zurich Isurace Irelad, i particular Dubli, thaks to the Iteratioal Fiacial Services Cetre (IFSC), is a global cetre of excellece for mid - to back office staff. bob keogh, director of goldma sachs bak (europe) Zurich cosidered a umber of optios ad Irelad best met our requiremets because of its log-stadig membership of the EU ad the Euro, a well developed isurace market ad a highly educated ad skilled workforce. These factors cotiue to uderpi our success ad drive our busiess forward both i Irelad ad across Europe. markus hogler, ceo zurich isurace plc ad chairma zurich life assurace plc

11 IRELAND The FACTS Populatio: 4.2 millio+ Geography: Irelad is a islad situated off the orth west of the Europea cotiet BELFAST Capital: Dubli Currecy: EURO / Laguage: Eglish. Irelad is the oly Eglish speakig euro zoe coutry Political ad legal system: Stable parliametary democracy. Irish law is based o commo law, legislatio, the Irish Costitutio ad EU law. GALWAY DUBLIN Trasport ifrastructure: Well developed iteratioal ad iteral trasport services. The islad of Irelad has a umber of large iteratioal airports ad ports - most Europea cities are accessible withi 2 to 3 hours flyig time ad there are direct flights to the USA. LIMERICK Fiacial ifrastructure: A very well developed ad sophisticated bakig ad fiacial services ifrastructure with established experiece i hadlig the requiremets of overseas compaies. CORK Pro-busiess ifrastructure: Irelad is recogised as oe of the most attractive locatios for iteratioal compaies to access the EU iteral market.

12 CONTACTS To discuss ivestig i Irelad ad how best to proceed for the beefit of your busiess, cotact ay of the followig: Liam Quirke dubli T E liam.quirke@mop.ie Robert O Shea dubli T E robert.oshea@mop.ie Pat Eglish dubli T E pat.eglish@mop.ie Joh Rya ew york T E joh.rya@mop.ie Mark O Sulliva palo alto T E mark.osulliva@mop.ie Staley Watso lodo T +44 (0) E staley.watso@mop.ie Matheso Ormsby Pretice advises iteratioal compaies ad fiacial istitutios doig busiess i ad through Irelad, icludig 27 of the world s 50 largest baks ad more tha half of the Fortue 100 compaies. Matheso Ormsby Pretice has the resources ad experiece to provide a comprehesive ad first-class service to iteratioal cliets. The firm provides pragmatic, tailored legal ad tax advice i the format that best suits our cliets eeds. With offices i Dubli, Lodo, New York ad Palo Alto, Califoria, the firm is uiquely positioed, with uparalleled experiece, to work with orgaisatios lookig to establish i Irelad. We look forward to hearig from you.

13 The Iformatio i this documet is provided subject to the Legal Terms ad Liability Disclaimer cotaied o the Matheso Ormsby Pretice website. The material is ot iteded to provide, ad does ot costitute, legal or ay other advice o ay particular matter, ad is provided for geeral iformatio purposes oly. DUBLIN LONDON NEW YORK PALO ALTO dubli 70 Sir Joh Rogerso s Quay Dubli 2 Irelad t f e mop@mop.ie lodo 16th Floor, Hero Tower 110 Bishopsgate Lodo EC2N 4AY Eglad t F E lodo@mop.ie ew york 245 Park Aveue New York NY USA t f e ewyork@mop.ie palo alto 530 Lytto Aveue Palo Alto CA USA t f e paloalto@mop.ie drive by excellece