Accelerated growth? Sustainable growth? Budget Tax Alert 2016

Transcription

1 Accelerated growth? Sustainable growth? Budget Tax Alert 2016

2 Contents 2 Budget reaction...3 Personal taxation...5 Business taxation...8 Entrepreneurial incentives...10 Property...11 Agri-taxation/farming measures...12 Indirect taxation...13 Miscellaneous...14 Rates at a glance...15 Case studies...16 Tax contacts...19

3 Budget reaction Kevin McLoughlin, Head of Tax Services 3 In last year s Budget speech the Minister for Finance, Michael Noonan TD recalled the Robert Frost poem The Road Not Taken. He indicated that the road ahead of us diverges and we have a choice to make. Do we take the road frequently trodden by Irish Governments in the past, a road whose signposts are tax and spend where one s journey is through boom to bust? Or do we, like Frost, take the road less travelled by? A road whose milestones are prudence and caution. For a less travelled road the journey towards the next election surely seems familiar. This time around though, it s a Fine Gael led coalition Government that has managed to stay the distance and be in the position to reap the rewards of four years of fiscal prudence. With a fiscal adjustment of 1.5bn, Budget 2016 seeks to reverse many of the tax increases and social welfare cuts that stand in the way of the re-election route and by so doing seeks to neuter the hounds of anti-austerity ready to nip at the heels of Government candidates. Spreading the good news is expensive. The main beneficiaries will be those USC taxpayers that contributed most to the exchequer in its time of need with 1.5% cut in the Universal Social Charge likely to have employees running for their calculators vision is very useful and through the murky battlefield of the next election, Minister Noonan has presented the visage of the complete abolition of the USC by Perhaps more importantly the reduction in the USC brings the marginal rate down to 49.5% for many, signalling the Government s intention to reward work. It has long been a fundamental principle of tax equity that taxpayers in comparable situations should pay comparable amounts of tax. The news that a tax credit will be phased in for the self-employed and farmers to match the employee tax credit given to PAYE workers will be welcomed by the self-employed many of whom earn relatively low income. Budget 2016 starts the process with a 550 tax credit. This is still 1,100 short of the equivalent PAYE tax credit. To add salt to the wound, the 3% discrepancy in marginal tax rates remains a more significant inequality. For businesses, the USC reductions might reduce some upward pressure on demands for pay rises and thus help maintain competitiveness. The fine print of a new 20% capital gains tax rate for entrepreneurs will no doubt be explored when the Finance Bill is published next week, coincidentally on EY Entrepreneur of the Year final night. However, the relief falls far short of expectations given its capital gain cap of 1mn. This forms part of a package of measures designed to bolster Ireland s support for entrepreneurs.

4 Budget reaction (continued) 4 Separately, the parameters of the best in class Knowledge Development Box will also be revealed next week. However, it remains to be seen whether the announcement of a 6.25% rate will dispel some foreign direct investment concerns that the regime will be uncompetitive against other countries patent box regimes that for some years will remain unconstrained by OECD rules. The 5 increase in children s allowance combined with the introduction of paid paternity leave and an extension of pre-school childcare will appeal to families while pensioners will receive an increase in their pensions as well as a higher Christmas bonus, just in time for the next election. Budget 2016 no doubt seeks to make the road towards the next election somewhat less frosty. Whether this demonstration of the rewards of stability will thaw the electorate sufficiently will be known in due course. The risk perhaps is that such an expansionary budget might actually overheat an economy expected to grow at 6.2% in 2015 especially if it creates unsustainable expectations of future largesse. With a fiscal adjustment of 1.5bn, Budget 2016 seeks to reverse many of the tax increases and social welfare cuts that stand in the way of the re-election route and by so doing seeks to neuter the hounds of anti-austerity ready to nip at the heels of Government candidates.

5 Personal taxation 5 Universal Social Charge (USC) Changes to the USC were well flagged in advance of the Budget. The Minister has gone for a straightforward approach of reducing the headline rates of USC, and unlike last year s Budget, has not introduced any counterbalancing measures to claw back some of the benefit from higher earners. All taxpayers will therefore benefit to some extent. The largest reduction will be in the 7% rate, which currently applies on income between 17,576 up to 70,044. This rate will be reduced to 5.5% for For those earning 70,044 or more, the USC reductions will translate into a net gain of 902 per year. It s not all good news however the top rate for PAYE taxpayers with income above 70,044 remains at 8%. Nevertheless, in his closing remarks, the Minister did indicate an intention to progressively abolish the USC, which is to be welcomed, although no indication has been given of the likely time frame.

6 Personal taxation (continued) 6 PRSI changes Minor changes were made to the employer and employee PRSI thresholds in relation to low-income earners. There has been an increase in the weekly entry point at which the top rate of employer PRSI of 10.75% is due from 356 to 376. In relation to employees, the weekly PRSI entry point remains at 352. To ensure that low income employees benefiting from the increase to the minimum wage are not penalised from breaching this threshold, a tapered relief has been introduced. This will ensure that the benefits of the increase to the minimum wage are not lost in employee PRSI contributions. Unfortunately, the opportunity was not taken to align the social security position of low-income self-employed taxpayers to those of employees. The self-employed become subject to PRSI once their annual earnings exceed 5,000 compared to 18,304 for employees and the minimum level of contributions for a self-employed taxpayer is 500. Earned Income Credit An Earned Income Credit has been introduced as an initial measure in the process of aligning the taxation of self-employed taxpayers and employees. The earned income credit of 550 will be available to taxpayers with self-employed income and business owners/managers who are ineligible for the PAYE credit on their salary income. However, the level of the credit does fall some way short of the PAYE credit which is worth 1,650 to an employee. While the reduction in the USC rates will equally benefit the selfemployed and employed in the low and middle income brackets, the USC surcharge of 3% for the self-employed on income over 100,000 is still in place. With a top marginal tax rate of 55% for the self-employed compared to 52% for employees, there is still a long way to go to tax equalise self-employed and employed taxpayers. However, it is expected this disparity will be addressed in future budgets.

7 Personal taxation (continued) 7 Home Carer Credit With effect from 1 January 2016, the Home Carer Credit will increase from 810 to 1,000. The Home Carer Credit is available to married couples/civil partners where one spouse/ partner cares for a dependent person. A dependent person is a child for whom child benefit is received or, a person aged 65 years or more or, a person who is permanently incapacitated. In addition to the increase in the credit, with effect from 1 January next, a Home Carer will be able to earn up to 7,200 in their own right (formerly 5,080) without impacting on the entitlement to the credit. Woodlands exemption The Minister has announced that profits or gains from the occupation of woodlands are to be removed from the scope of the High Earners Restriction. Income derived from the occupation of woodlands has been exempt from income tax for many years. This exemption is part of a longstanding policy to encourage the development of forestry and the production of native timber supplies. Notwithstanding this, changes to the income tax system in recent years resulted in a situation where, in certain circumstances, individuals who invested in forestry found themselves facing tax liabilities when they eventually realised profits from the sale of the standing timber or other forestry products. This was as a result of the application of the High Earners Restriction, which in certain circumstances limits the benefit of certain tax reliefs and incentives. Due to changes in recent years, this potentially kicked in where the amount of specified reliefs claimed in a year, including the woodlands exemption, exceeded 80,000. The announcement that woodlands relief is to be removed from the scope of the High Earners Restriction is to be welcomed.

8 Business taxation 8 Knowledge Development Box The Minister announced that Finance Bill 2015 will include legislation to introduce an Irish Knowledge Development Box (KDB) from 1 January Qualifying income under the KDB will be taxed at a rate of 6.25%. The KDB was proposed in last year s Budget speech and has been subject to consultation with relevant bodies including EY. The Department of Finance has stated that the KDB will be best in class whilst being compliant with the OECD Nexus Approach. The Irish KDB has been publicised by the Department as being the first OECD compliant box helping to give certainty to companies investing in Ireland. The mechanics of the KDB will be included in the Bill. The key issues raised by EY with the Department to date are: Ensure that the definition of Qualifying Asset is as broad as possible within the OECD guidelines. Include capital gains and income from sale of Qualifying Assets within the definition of Qualifying Income. Include expenditure incurred on patents pending as Qualifying Income. Draft the legislation such that income from R&D services can be included as Qualifying Income. The mechanics for tracking and tracing of the elements of the formula should be clarified to remove uncertainty and reduce the administrative burden for companies availing of the KDB. The KDB is a further addition to Ireland s existing portfolio of incentives to encourage investment in innovation activities in Ireland. It will only be possible with hindsight to measure if the KDB combined with the 12.5% trading rate for companies, the R&D tax credit and tax depreciation rules for intangible assets has been successful. As competitor countries introduce their own OECD compliant regimes, Ireland may need to make changes to the KDB to ensure that it remains best in class, including the rate. EY will continue to engage with the Department and provide feedback on any draft guidance notes.

9 Business taxation (continued) 9 Country by Country Reporting As expected Ireland is introducing Country by Country Reporting (CBCR) in line with OECD s agreed minimum standard and we would expect Ireland to follow the template proposed by the OECD without amendment. Starting in January 2016, the rules will apply to MNCs headquartered in Ireland with consolidated revenues in excess of 750mn. Significant effort and cost will be required to comply with this reporting obligation. For any Irish head-quartered financial institution and certain Irish subsidiaries of financial groups, the obligation has to be introduced alongside the similar (but not identical) Country by Country Reporting obligations under CRD IV, which have been in place since mid In addition, businesses will be concerned about the use of this data by tax authorities. The intention is that the information will be used for risk assessment and not as an alternative to proper evaluation of the tax position of affiliates of an MNC in a given territory. This concern was well aired in the OECD consultation. Only time will tell whether the reality accords to the intent. Three year relief for start-up companies The current relief from corporation tax for new start-up companies in their first three years of trading will be extended for a further three years until the end of This is a welcome measure for the SME sector. The potential tax saving over the three year start up period is 120,000. Aviation services facilities The 2013 Finance Act introduced legislation to facilitate the grant of capital allowances for capital expenditure incurred on the construction of certain aviation services facilities. The grant of allowances was limited to expenditure incurred on buildings or structures constructed in specific regionally assisted areas, such as Shannon airport. The introduction of the relief was subject to a commencement order from the Minister of Finance. It is now proposed to remove the limitation regarding the location of the buildings or structures, subject to an introduction of a cap on the amount of expenditure on which allowances are claimed. It is also proposed that the relief will come into force from 13 October Bank Levy The Bank Levy was originally introduced for the three year period from 2014 to However, it is now proposed that the levy will be extended to 2021, at the current level of 150mn per annum, subject to a review of the calculation methodology. For , the levy is almost exclusively borne by those banks which take deposits from domestic retail customers, as the amount is proportionate to DIRT payments for the base year of The intended review of the levy methodology is likely to be monitored by the international banks in Ireland to check that the levy s scope does not extend materially into that sector. The extension will be an unwelcome addition to the domestic banks overall levy burdens, coming at the time of introduction of the Eurozone s new Single Resolution Fund levy. The Resolution Fund levy aims to raise, in Ireland, 75mn per annum rising to a maximum of 225mn per annum, over eight years, from the domestic and international sector.

10 Entrepreneurial incentives 10 Capital gains tax entrepreneur relief A relief for entrepreneurs was introduced in 2013, and applies where the proceeds of disposals of assets made on or after 1 January 2010 are reinvested in new business ventures in the period 1 January 2014 to 31 December The relief is granted in the form of a tax credit against any capital gains tax liability arising on the ultimate disposal of the business assets more than 3 years after they were acquired. The existing relief is likely to have very limited application. Budget 2016 announced a further CGT relief for entrepreneurs with effect from 1 January 2016, in the form of a reduced CGT rate of 20% and applies on the disposal in whole or in part of a business up to an overall limit of 1mn in chargeable gains. The relief is an improvement on the existing relief and further enhances a pro-business tax regime for entrepreneurs. However the rate of 20% and the cap of 1mn might be considered by entrepreneurs as not going far enough. Employment and Investment Incentive (EII) The EII scheme allows an individual investor to obtain tax relief on investments in certain Irish companies up to a maximum of 150,000 per annum in each tax year up to Relief is initially available at 30%. A further 11% tax relief applies where it is shown that employment levels have increased at the company at the end of the specified holding period, or where evidence is provided that the company used the capital raised for expenditure on research and development. The maximum investment by all investors in any one company or group of companies is currently 10mn subject to a maximum of 2.5mn in any one twelve month period. Budget 2015 increased the specified holding period from three years to four years and the amount of finance that can be raised by a company or group of companies under the EII to 5mn annually subject to a lifetime maximum of 15mn. The changes were subject to approval from the European Commission and are now being commenced. It is now proposed that investment in the management and operation of nursing homes, mediumsized enterprises in non-assisted areas, and internationally traded financial services that are certified by Enterprise Ireland will qualify under the scheme. Budget 2016 amends the scheme to include expansion works on existing nursing homes. The EII scheme is also to be extended to all qualifying small and medium enterprises, regardless of geographic location in Ireland.

11 Property 11 Increasing supply of residential housing Minister Noonan announced that NAMA will work with developers to create 20,000 residential housing units by 2020, while being consistent with delivering a financial return to the taxpayer. NAMA will use 100 active sites to build these 20,000 units, of which 90% will be in Dublin and 75% will accommodate the starter home market. While this measure will help the sector, the government has not done enough to help alleviate the chronic shortage of residential homes in the country. Local Property Tax The Budget proposed to delay until 2019, the revaluation of residential property for the Local Property Tax. This comes from the recommendations provided in the review of the local property tax which is being published in line with this Budget. This will mean any increases that would have been inevitable due to the rising property market (largely in Dublin) since inception of the Local Property Tax, will be postponed until Home renovation incentive (HRI) The extension of the HRI to 31 December 2016 was confirmed. Capital Acquisitions Tax (CAT) The Group A threshold applicable to gifts and inheritances received by children has been increased from 225,000 to 280,000. There has been no change to other thresholds and the rate of CAT remains at 33%. The change applies to gifts and inheritances received on or after 14 October 2015.

12 Agri-taxation/ farming measures 12 The stamp duty exemption for young trained farmers is extended to 31 December The Minister announced a new succession transfer provision to encourage the transfer of the family farm to the next generation. The provision provides for an income tax credit worth up to 5,000 per annum for five years, to be split according to a family partnership profit sharing agreement. The partnership agreement must provide for the transfer of the farm to the young farmer at the end of a specified period, not exceeding 10 years.

13 Indirect taxation 13 Reduced motor tax rates on commercial goods vehicles The rate of motor tax for all commercial goods vehicles above 4,000kgs, are to be reduced with a new annual rate of 500 for vehicles between 4,000kgs and 12,000kgs and 900 for vehicles over 12,000kgs. This will produce annual motor tax savings from between 43 at the lower end and 4,295 at the upper end. This should benefit over 28,000 commercial vehicles. It is to apply from 1 January 2016 as an interim measure pending the replacement of the current motor tax regime. The measure is designed to reduce the distortion in the cost of motor tax for large goods vehicles in Ireland by comparison to that applying in Northern Ireland and the rest of the UK and is expected to benefit the industry by 43mn per year. Microbreweries There is an existing relief reducing the standard rate of alcohol products tax by 50% on beers produced in microbreweries which produce not more than 30,000 hectolitres per annum. The Minister announced that this relief will now be available upfront as well as through a rebate thereby providing a cash-flow benefit to microbreweries. Tourism sector The Minister announced the retention of the 9% VAT rate for the tourism sector for a further year. However, he noted that the case for retaining the rate is diminishing each year as room rates are rising particularly in Dublin. Tobacco products The Minister announced that the excise duty on a packet of 20 cigarettes is being increased by 50 cents (including VAT) with effect from midnight on 13 October The Minister stated that this will bring the price of a packet of 20 cigarettes in the most popular price category to There is a pro-rata increase on other tobacco products with effect from the same date. The measure is expected to raise 61.4mn in a full year.

14 Miscellaneous 14 Abolition of pension levy The pension fund levy was originally introduced in 2011 to fund the reduction of the VAT rate in the tourism sector. The Government has announced that this is no longer required and therefore the pension fund levy of 0.15 %, introduced for 2014 and 2015, will be abolished from 2016 onwards. Stamp duty on bank cards Stamp duty on ATM and combined ATM/debit cards is being modified to a 12c charge on ATM transactions only, capped at the previous flat charge of 2.50/ In conjunction with the Minister s announced halving of interchange fees on debit card transactions, card issuers will face some financial and operational impact. Film relief Subject to EU State Aid approval it is proposed to increase the cap on eligible expenditure under this relief from 50mn to 70mn.

15 Budget 2016 Rates at a glance Income Tax Rates Standard 20% Marginal 40% Standard Rate Bands Single 33,800 Married 67,600 Married - one income 42,800 Single parents 37,800 Income Tax Credits Single 1,650 Married 3,300 Single person child carer tax credit (primary carer only) 1,650 PAYE 1,650 Earned income credit 550 Age credit - single (married x2) 245 Medical insurance relief max premium - adult/child 1,000/ 500 Home carer credit 1,000 Income Tax age exemption Single and widowed 18,000 Married (either spouse aged 65 or over) 36,000 Preferential loan specified rates - benefit in kind Qualifying home loans 4% All other loans 13.5% Universal Social Charge Earnings 0-12,012* 1% 12,013-18,668 3% > 18,688 and < 60,000 aged 70 and 3% over (medical card) 18,669-70, % > 70, ,000 8% PAYE income > 100,000 8% Self employed income > 100,000 11% *exempt if income < 13,000 PRSI Rates Employer Standard rate 10.75% Lower rate 8.5% Weekly lower rate limit 376 Self-employed PRSI 4% Minimum contribution 500 Employee PRSI 4% PRSI Weekly PRSI threshold 352 Introduction of PRSI relief on tapered basis up to 12 per week Relief tapers out as income reaches 424 per week Pensions Annual earnings cap 115,000 Marginal rate deduction 40% Tax free lump sum limit 200,000 Standard fund threshold 2,000,000 Pension fund levey (down 0.15%) 0 DIRT Deposit accounts 41% Investment funds 41% Property Charges Local Property Tax Market value < 1,000, % Excess value > 1,000, % Revaluation date postponed until 2019 Capital Gains Tax Standard rate 33% Withholding tax rate 15% Annual exemption 1,270 Reduced entrepreneur capital gains tax rate 20% on disposal in whole or in part of a business up to 1mn chargeable gains introduced from 1 January 2016 Capital Acquisitions Tax Standard rate 33% Thresholds Group A (up 55,000 from 14 Oct 15) 280,000 Group B 30,150 Group C 15,075 Stamp Duty Residential property First 1,000,000 1% Excess over 1,000,000 2% Non-residential property 2% Corporation Tax Rates Standard Rate 12.5% Higher rate on passive income 25% Knowledge Development Box (KDB) incentive for conducting R&D in Ireland Income that qualifies for KDB subject to 6.25% reduced rate of corporation tax (start date to be included in the Finance Bill) Extension of 3 year corporation tax relief for start up companies to 2018 VAT Rates and limits Standard rate 23% Reduced rate 13.5% Reduced rate (certain goods and 9% services) Farmer s flat rate 5.2% Distance selling limit 35,000 Registration limit - taxable goods 75,000 Registration limit - taxable services 37,500 Cash receipts basis limit 2,000,000 Excise duties Excise duty on a packet of 20 cigarettes + 50 cent (Pro rata increase on other tobacco products) Excise relief for micro breweries available up front

16 Case studies Scenario 1 Marie is 30 and a single mother with a 3 year old daughter. She is a marketing consultant and earns 70,000 per annum. She lives in a house in Cork. 16 Single working mum plus one child 2015 Budget 2016 Budget Difference Gross Income 70,000 70,000 0 Income Tax Payable 15,490 15,490 0 Universal Social Charge 4,045 3, PRSI 2,800 2,800 0 Child Benefit 1,620 1, Net income 49,285 50, Change as a % of net income 1.95% Scenario 2 Peter and Fiona are married. Peter is an accountant and Fiona is a homemaker. Peter earns 90,000 per annum as a self-employed person from his own accountancy practice. They have three children aged 4, 7 and 9. Married couple, one earning plus three children 2015 Budget 2016 Budget Difference Gross Income 90,000 90,000 0 Income Tax Payable 23,330 22, Universal Social Charge 5,644 4, PRSI 3,600 3,600 0 Child Benefit 4,860 5, Net income 62,286 63,918 1,632 Change as a % of net income 2.62%

17 17 Case studies Scenario 3 James and Mary are married. James is a supervisor and earns 36,000 per annum. Mary is a part-time hairdresser and earns 12,500 per annum. They have two children aged 19 and 21. Both children are attending third level colleage full-time and live at home. Married couple, both earning and two adult children 2015 Budget 2016 Budget Difference Gross Income 48,500 48,500 0 Income Tax Payable 3,100 3,100 0 Universal Social Charge 1,862 1, PRSI 1,440 1,440 0 Net income 42,098 42, Change as a % of net income 1.40% Scenario 4 Victoria and Patrick are a retired couple. Patrick is aged 70 and Victoria is aged 74. Patrick has a Contributory State Pension of 22,703 in 2015 and an occupational pension of 90,000 per annum. Retired couple, one with pension income 2015 Budget 2016 Budget Difference Gross Income 112, , Christmas Bonus Income Tax Payable 31,125 31, Universal Social Charge 5,644 4, PRSI Net income 76,043 77,257 1,214 Change as a % of net income 1.60%

18 18 Case studies Scenario 5 Sean and Lisa are married. Sean is 55 and is a hospital consultant. He has annual employment earnings of 180,000 and consultancy earnings from his private practice of 130,000. Lisa is a homemaker. Sean plans to make a pension contribution of 35,000. Sean also owns a rental property, valued at 370,000 with net rental income of 20,000. They have one child under five years, who is incapacitated. Married couple, one earning with investment income, 2015 Budget 2016 Budget Difference making a pension contribution of 35,000 plus one child Gross Income 330, ,000 0 Income Tax Payable 100, , Universal Social Charge 26,344 25, PRSI 13,200 13,200 0 Child Benefit 1,620 1, Net income 156, ,848 1,152 Change as a % of net income 0.74% Scenario 6 Kate is 28. She works in a restaurant and earns the minimum wage for an average of 39 hours per week. Kate lives in an apartment in Sligo. Single, minimum wage 2015 Budget 2016 Budget Difference Gross Income 17,542 18,556 1,014 Income Tax Payable Universal Social Charge PRSI Net income 16,960 17, Change as a % of net income 4.18%

19 19 Tax contacts EY Assurance Tax Transactions Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. Kevin McLoughlin Head of Tax Services Tel: kevin.mcloughlin@ie.ey.com Dublin Joe Bollard International Tax Services Tel: joe.bollard@ie.ey.com Breen Cassidy Indirect Tax Services Tel: breen.cassidy@ie.ey.com Sarah Connellan People Advisory Services Tel: sarah.connellan@ie.ey.com Sandra Dawson Financial Services, Insurance Tel: sandra.dawson@ie.ey.com John Hannigan Financial Services, Aviation Tel: john.hannigan@ie.ey.com Dan McSwiney Transfer Pricing Services Tel: dan.mcswiney@ie.ey.com Aidan Meagher Corporate Tax Services, Life Sciences Tel: aidan.meagher@ie.ey.com Ray O Connor Financial Services, Banking Tel: ray.oconnor@ie.ey.com Eamonn O Doherty Corporate Tax Services Tel: eamonn.odoherty@ie.ey.com Declan O Neill Transactions Tax Services Tel: declan.oneill@ie.ey.com Donal O Sullivan Financial Services, Wealth and Asset Management Tel: donal.osullivan@ie.ey.com Jim Ryan People Advisory Services Tel: jim.ryan@ie.ey.com Colin Smith Corporate Tax Services Tel: colin.smith@ie.ey.com David Smyth Financial Services Tel: david.smyth@ie.ey.com Aidan Walsh Financial Services, International Banking Tel: aidan.walsh@ie.ey.com Cork Frank O Neill Corporate Tax Services Tel: frank.oneill@ie.ey.com Limerick John Heffernan Private Client Services Tel: john.heffernan@ie.ey.com Waterford Paul Fleming Corporate Tax Services Tel: paul.fleming@ie.ey.com New York Irish Tax Desk Karl Doyle Corporate Tax Services Tel: karl.doyle@ey.com EY refers to the global organisation and may refer to one or more of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. For more information about our organisation, please visit ey.com Ernst & Young. Published in Ireland. All Rights Reserved indd 10/15. Artwork by the BSC (Ireland) ED 0617 The Irish firm Ernst & Young is a member practice of Ernst & Young Global Limited. It is authorised by the Institute of Chartered Accountants in Ireland to carry on investment business in the Republic of Ireland. Ernst & Young, Harcourt Centre, Harcourt Street, Dublin 2, Ireland. Information in this publication is intended to provide only a general outline of the subjects covered. It should neither be regarded as comprehensive nor sufficient for making decisions, nor should it be used in place of professional advice. Ernst & Young accepts no responsibility for any loss arising from any action taken or not taken by anyone using this material. ey.com