Finance Bill Click here to view table of contents

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1 Finance Bill 2014 Click here to view table of contents

2 2 Contents Finance Bill published... 3 Personal taxation... 4 Business taxation... 6 Financial services... 8 Pensions... 9 Agri-taxation Property Indirect taxation Miscellaneous and anti-avoidance What s next Rates at a glance Tax contacts... 20

3 Finance Bill published 3 On 23 October the Government published Finance Bill The Bill primarily seeks to implement the tax elements of the 2015 Budget measures announced on 14 October. At 125 pages it continues the trend in recent years towards shorter Finance Bills. In addition to providing more detail of Budget 2015 proposals, it also contains some previously unannounced technical, administrative and anti-avoidance measures. These new provisions include a significant overhaul of the general anti-avoidance rules and related reporting by promoters of transactions with certain tax avoidance characteristics and the introduction of restrictions on the use of trading losses by part-time traders. There are also some measures linked to the inappropriate use of Approved Retirement Funds (ARFs) and other postretirement funds.

4 Personal taxation 4 Personal taxes Other than those already flagged in Budget 2015, the Bill contains few new personal taxation measures of significance. It legislates for the 1% reduction in the marginal income tax rate and the USC changes announced in Budget Tax relief under the Employment and Investment Incentive scheme is given in two instalments with the second instalment, a credit of 11/41sts of the investment, being payable once certain employment criteria are met. The first and second instalments will be adjusted to credits of 30/40ths and 10/40ths respectively to ensure relief is reduced in line with the 1% reduction in the marginal rate. Loss relief The Bill introduces restrictions on the use of trading losses by an individual carrying on a trade or profession in a non-active capacity, subject to certain exceptions, e.g. for farming, market gardening, Lloyd s underwriting and capital allowances. An individual will be considered to carry on a trade or profession in a non-active capacity if the individual does not work on average at least 10 hours per week personally in the activities of the trade or profession such activities being carried on on a commercial basis with the view to the realisation of profits. Where the restriction applies, the offset of any relevant loss against other income will be capped at 31,750 per annum. It is also provided that where an individual makes a loss on trading that derives from tax avoidance arrangements designed to generate that loss then no amount of the loss may be offset against other income. The carry-forward of losses is unaffected.

5 Personal taxation (continued) 5 SARP and FED The changes referred to in Budget 2015 to the SARP and FED regimes are included in the Bill. The list of new countries included in the FED scheme now includes travel to Japan, Singapore, South Korea, Saudi Arabia, the UAE, Qatar, Bahrain, Indonesia, Vietnam, Thailand, Chile, Oman, Kuwait, Mexico and Malaysia, but only from Likewise the SARP improvements to the qualification criteria will only apply to individuals arriving in Ireland from 1 January 2015; individuals arriving in Ireland prior to 2015 cannot benefit except to the extent that they already qualify for SARP but in that instance they will benefit from the elimination of the 500,000 income ceiling. Miscellaneous The Bill contains a small number of measures to comply with EU law. One such measure is the extension of income tax relief for mortgage interest on loans used to acquire, improve etc. a qualifying principal private residence in any European Economic Area (EEA) State rather than just Ireland or the UK. Domicile levy Additional information powers will be given to the Revenue to pursue non-compliance with the domicile levy provisions. The Revenue will be empowered to request the completion of a return where it has reason to believe an individual is liable for the domicile levy. The Bill also extends tax geared penalty provisions to the domicile levy. Finally, the Bill removes any entitlement of Government ministers to claim tax deductions for local property tax or water charges as an expense of maintaining a second residence.

6 Business taxation 6 Corporate tax residence changes The Bill confirms the Budget announcement that the Irish law allowing Irish incorporated companies to remain non-resident is to be repealed with effect for companies incorporated on or after 1 January Companies incorporated in Ireland after that date will be considered tax resident in Ireland unless a relevant double taxation agreement provides otherwise. Companies incorporated before 1 January 2015 can be non-irish tax resident for a limited period. Assuming central management and control of the company is exercised outside of Ireland and the stateless company rules introduced in 2013 do not apply, the company may be able to maintain non-irish resident status until 31 December This reasonable transition period is important to enable companies restructure themselves in a controlled manner. The Bill confirms that a company incorporated in a foreign country that is centrally managed and controlled in Ireland will continue to be treated as resident in Ireland for tax purposes. R&D and Intangible assets The Bill contains no surprises on the R&D front. It confirms the abolition of the R&D base year with effect for relevant periods commencing on or after 1 January This should make the regime much more attractive to companies that incurred substantial R&D in 2003 and that wish to continue to do so in the future. The Bill confirms the removal of the 80% cap on the annual utilisation of capital allowances for specified intangible assets with effect for accounting periods commencing on or after 1 January While some companies may well have claimed capital allowances for expenditure incurred on acquiring customer lists already, the specific inclusion of such assets within the capital allowance regime (other than where the customer list is acquired in connection with a transfer of a business) provides welcome clarity with effect for accounting periods commencing on or after 1 January With effect for specified intangible assets transferred on or after 23 October 2014, where an asset is transferred to a connected company after a five year period no balancing charge is imposed on the transferor as before. However an acquiring company will be able to claim capital allowances on the expenditure up to the amount of the tax written down value of the asset remaining at the time of transfer. The above measures further enhance the attractiveness of Ireland as a location for developing and holding intellectual property with the promise of more to come in the form of a best in class knowledge development box in Finance Bill 2015.

7 Business taxation (continued) 7 Film corporation tax credit A number of amendments are being made to the film corporation tax credit which, subject to EU approval, is due to commence on 1 January The requirement that a qualifying company distribute films will be removed. The minimum eligible expenditure Is being reduced from 200,000 to 125,000 to comply with State Aid rules and the requirement that principal photography must not commence prior to making an application under the scheme is to be removed. This latter amendment is particularly welcome although start-ups still face difficulties with the manner in which the relief is given. Unfortunately, the opportunity was not taken to amend the definition of broadcaster which currently precludes many foreign film studios from establishing Irish production companies that might avail of the credit. Accounting standards A technical provision in the Bill confirms that the existing transitional rules introduced to cater for moves from Irish GAAP to IFRS will also apply to transitions to FRS 102 with effect for accounting periods beginning on or after 1 January As tax generally follows the accounting treatment unless the law says otherwise, the Bill is a timely reminder that all companies not already using IFRS will need to consider the tax implications of a mandated move to either IFRS or FRS 102 sooner rather than later to avoid surprises. Accelerated capital allowances for energy-efficient machinery Budget 2015 announced an extension of accelerated capital allowances for capital expenditure incurred on energy-efficient equipment up to 31 December The Bill also amends the descriptions of the classes of technology that qualify under the scheme. Entrepreneur relief The Bill contains a number of amendments to the CGT relief for entrepreneurs with the stated aim of making the relief more effective.

8 Financial services 8 Deposit interest retention tax (DIRT) The Bill does not adjust the rate of deposit interest retention tax which is to remain at 41%. Likewise the rate of tax imposed on exit from investment funds and life assurance policies is also to remain at 41%. It might have been expected that the rate would reduce in line with the reduction in the rate of income tax although this was not inevitable given that deposit interest etc. is not liable to the USC and thus the offsetting Budget 2015 increase in the 7% USC rate to 8%. Amendment of Section 80A of Principal Act (taxation of certain short-term leases of plant and machinery) The Finance Act 2010 provisions relating to the taxation of short term operating leases of plant and machinery have been relaxed with the removal of the original threshold period restrictions on allowances, thereby effectively accelerating their capital allowances claims. This change should make it more attractive for lessors to elect into the section 80A provisions for the taxation of their short term operating lease portfolios. Alternative Investment Funds Following the transposition of the Alternative Investment Fund Managers Directive into Irish law in 2013, the existing provisions that exempt UCITS from Irish taxation are extended to Alternative Investment Funds which are managed by a management company authorised in Ireland or the EEA.

9 Pensions 9 Approved Retirement Funds - ARFs The Bill makes a number of amendments to the ARF legislation, stated as being required to combat a number of avoidance schemes connected to the use of ARFs and other forms of post retirement funds. These proposed amendments mainly clarify what is considered a distribution from an ARF and seek to ensure that tax is applied to such a distribution. In summary, the provisions provide that: Any assignment of an ARF or of assets out of an ARF by any person is regarded as a distribution from the ARF distributions from ARFs are subject to income tax, together with USC and PRSI, where applicable. Any distribution in relation to an ARF is to be deemed to be made by a Qualifying Fund Manager (QFM) and therefore subject to tax. Under the legislation, the QFM is responsible for the deduction of tax on an ARF. Where ARF assets are used to invest in a scheme that also involves an investment by a pension arrangement belonging to a person connected to the owner of the ARF, any arrangement whereby the investment return to that pension arrangement is attributable in any way to the ARF owner s investment will trigger a taxable distribution from the ARF of an amount equal to the value of the ARF assets used in the investment. A distribution will also be treated as arising to any such investment in a scheme undertaken by the owner of a vested PRSA or an Approved Minimum Retirement Fund (AMRF). The Bill also introduces a new provision to ensure that any investment returns to the pension arrangement of the connected person will be subject to income tax in the hands of the trustees or administrator of that arrangement. The above amendments are effective from 23 October 2014.

10 Pensions (continued) 10 Imputed Distribution Regime Where applicable, ARFs and vested PRSAs are deemed to make an annual imputed (deemed) distribution of 5% of the value of their assets and this amount is taxed at the individual s top income tax rate. USC and PRSI are also due if relevant. The Bill reduces the 5% rate to 4% for ARFs and vested PRSAs with asset values of 2 million or less where the owner of such a retirement fund is aged under 70 for at least part of the tax year. For the owner of an ARF or vested PRSA aged 70 or over for the whole tax year, the 5% imputed distribution rate continues to apply. Regardless of age the current 6% imputed distribution rate continues where the value of the ARF/vested PRSA is greater than 2 million. Approved Minimum Retirement Funds - AMRFs With effect from the 2015 tax year, the Finance Bill provides that the beneficial owner of an AMRF may draw down up to 4% of the value of the assets subject to tax. Prior to this proposed change no distribution, other than accumulated investment growth, could be taken from an AMRF until age 75. Maximum Tax Relieved Pension Fund - Standard Fund Threshold - SFT The Bill confirms that where a chargeable excess arises, above the SFT of 2 million or the Personal Fund Threshold (PFT) of the individual, the current rate of tax of 41% that applies to such chargeable excess is reduced to 40% with effect from 1 January This corresponds with the reduction in the higher rate of income tax from 41% to 40%. The Bill also contains amendments to the legislation dealing with the maximum allowable pension fund at retirement for tax purposes where a Pension Adjustment Order (PAO) is in place. The amendments provide that, chargeable excess tax is to be recovered from both the member and non-member spouse/ partner rather than from the member s part of the pension benefits solely which is the current position.

11 Agri-taxation 11 Budget 2015 s capital tax measures were primarily focused on the agri-sector. While the reaction was generally positive, some post budget concerns have arisen in connection with the critical change to agricultural property relief from CAT. This relief is to be refocused on active farmers or those who lease land on a long-term basis for use by active farmers. Further details of this are contained in the Finance Bill. An active farmer must spend not less than 50% of his or her normal working time farming agricultural property on a commercial basis and with a view to the realisation of profits. In addition to implementing Budget 2015 announcements, the Bill also provides the promised exemption from CGT on chargeable gains arising from the disposal by farmers of certain entitlements under the Single Payment Scheme on or before 15 May 2014.

12 Property 12 Real Estate Investment Trusts (REITs) There are two principal amendments pertaining to REITS. The first is an anti-avoidance measure designed to ensure that properties cannot be transferred into a REIT under corporate group provisions on a no gain/no loss basis. This mirrors a similar amendment made in 2008 for authorised investment companies although there are additional reporting requirements. The second amendment introduces an exemption for Deposit interest retention tax (DIRT) for REITs to ensure that an existing excemption from tax on such interest operates as intended. Living city initiative Some amendments are being introduced to the living city initiative scheme that provides for tax relief for conversions and refurbishments of certain pre-1915 properties. The relief has yet to be commenced. Single storey buildings are to be included and more information will be required in support of a claim. The Bill introduces an expenditure limit of 400,000 for individuals and 1.6m for companies. To comply with EU State Aid rules a maximum aggregate amount of relief of 200,000 will apply irrespective of the number of investors. Aviation services In order to comply with EU State Aid rules the entitlement to capital allowances on certain aircraft maintenance facilities (which was awaiting EU approval) has been modified so that allowances will only be available if the building or structure concerned is located in a regionally assisted area and meets EU Regional Aid Guidelines. Points to watch The Bill contains a few previously unannounced property measures. Two significant measures not included in the Finance Bill will need to be kept in mind. Firstly, property investors holding back from the market should be aware that the 7-year exemption attributable to acquisitions of investment properties before 31 December 2014 has not been extended. Secondly the 50% abatement of the 2% stamp duty rate on transfers of non-residential land between certain close relatives (known as consanguinity relief) will expire generally from 1 January 2015 except for certain transfers to active farmers by a transferor aged 65 years or under.

13 Indirect taxation 13 VAT exemption for golf green fees The Bill extends the scope of the current VAT exemption which applies to membership fees paid by members of member-owned or non-profit making golf clubs. The proposed amendment means that green fees payable by visitors to such clubs will also benefit from VAT exemption. The extension of the exemption was necessitated by the judgment of the Court of Justice of the European Union in December 2013 in the Bridport and West Dorset Golf Club case in which the Court held that the certain categories of persons could not be excluded from the benefit of the VAT exemption. Good news for herbal tea drinkers The Bill provides that the same VAT rates apply to the supply of tea and the supply of herbal teas. VAT exemption for defined contribution pension funds The Bill extends the scope of the VAT exemption for the management of special investment funds to the management of certain defined contribution pension schemes. The extension of the exemption was necessitated by the judgment earlier this year by the Court of Justice of the European Union in the ATP Pension Service A/S case. The Court held that defined contribution pension schemes are analogous to special investment funds and should benefit from the VAT exemption for the management of such funds. Record issuing and keeping The Bill contains a number of measures in relation to document retention and issuing. It requires linking documents in relation to a VAT issue which is the subject of a Revenue enquiry, a claim, an appeal or other proceedings, to be retained for a period of 6 years or, if longer, until such enquiry, appeal etc. is concluded. In an anti-evasion measure, Revenue can issue a notice requiring a business person to issue, in respect of each supply for which a VAT invoice is not issued, a document which contains all of the particulars required on a VAT invoice. The maximum period for which a notice can have effect is two months. Provision is also made for a penalty to apply in the event of failure to issue the required document.

14 Indirect taxation (continued) 14 Joint and several liability for reckless trading The Bill contains a further anti-evasion measure which provides for the imposition of joint and several liability in certain circumstances. The measure provides that Revenue can make a person jointly and severally liable for any tax due in relation to a transaction where that person participates in a supply or series of supplies of goods or services where they know, or are reckless as to whether or not, the supply or series of supplies is connected with the fraudulent evasion of VAT. Extension of VRT relief for electric and hybrid electric vehicles The Bill provides for the extension of the VRT relief on certain electric and hybrid electric vehicles. The relief, which can be worth up to 2,500 and which was available on such vehicles registered between 1 January 2011 and 31 December 2014 has now been extended to vehicles registered up to 31 December 2016.

15 Miscellaneous and anti-avoidance 15 As expected, the Bill contains a number of administrative and anti-avoidance provisions. General anti-avoidance rule (GAAR) The Bill significantly overhauls the general anti-avoidance rule in a number of respects. The existing rules will only apply to transactions commenced on or before 23 October 2014 There will no longer be a requirement for a Revenue officer to reach an opinion that a transaction is a tax avoidance transaction and issue a notice of such opinion to a taxpayer. This presumably will reduce the risk of a successful challenge to the reclassification of a transaction on a procedural point. Instead the benefit of the transaction will be withdrawn where it would be reasonable to consider based on specified factors that the transaction was a tax avoidance transaction and Revenue will simply issue an assessment on the person. Where additional tax arises as a result of any such assessment a surcharge of 30% of the tax advantage will arise (up from 20%) unless the taxpayer has made a protective notification to Revenue. The Bill also provides that where a person claimed the benefit of a tax advantage contrary to the GAAR or a specified anti-avoidance provision, that person may avail of a reduced surcharge amount if a disclosure is made to Revenue and the tax and interest is paid. The protection offered by protective notifications will no longer be available where the transaction was one which was disclosable to Revenue under the Mandatory Disclosure provisions unless the taxpayer was unaware that the transaction was a disclosable transaction. Promoters of certain transactions with certain tax avoidance characteristics may be required to disclose the transaction to Revenue. Many of the rules governing this process are contained in Regulations and the Bill incorporates these into primary legislation including a new discretionary trust hallmark. A new requirement is being introduced to facilitate the assignment of a unique Transaction Number (TN) to each notified scheme to Revenue and persons who enter into a transaction which is disclosable or who seek to benefit from such a transaction must enter this TN in their tax returns.

16 Miscellaneous and anti-avoidance (continued) 16 There is also a new requirement that following the determination of any appeal by the Appeal Commissioners involving a tax avoidance transaction or disclosable transaction, the Revenue may issue a notice requiring payment of the tax due on foot of the determination. A taxpayer may still appeal the determination but Revenue will have the benefit of the tax. It is worth noting that Revenue will also have the power to issue payment notices to other taxpayers who engaged in similar transactions. Finally, an opportunity for regularising compliance with the GAAR, arises in the form of a facility to make a qualifying avoidance disclosure. Where such as disclosure is made on or before 30 June 2015 the 30% surcharge referred to above will not apply and any interest due will be reduced by 20%. Relevant contractors tax (RCT) The penalties applicable to principal contractors who make unauthorised payments to subcontractors in the construction and certain other sectors have been restructured to provide for variable penalties ranging from 3% to 35% depending on the circumstances. Principal contractors will also now be obliged to submit unreported payment notifications. Charitable donations The Bill also provides for the retrospective removal of an eligible charity s authorisation from the date a charity ceased to comply with the relevant conditions for authorisation. This impacts the relevant charity as any tax relief obtained on donations by companies and self-employed individuals will not be disturbed assuming the donation was made in good faith. Non-residents and capital gains The tax code contains an anti-avoidance provision designed to counter the avoidance of CGT by individuals who become temporarily non-resident for tax purposes. It provides that certain assets disposed of in any year of non-residence are deemed to be disposed of and reacquired on the last day of the year of departure and thereby imposing a charge to CGT. The amendment provides that the market value of the assets on the date of actual disposal will be used for the purpose of calculating the capital gain/loss. The amendment applies regardless of whether there has been an increase or decrease in the market value of the assets since the year of departure.

17 Miscellaneous and anti-avoidance (continued) 17 Vodafone shares Vodafone shareholders that received a return of value earlier this year following the Verizon spin-off and who failed to make a timely election for capital treatment received a Finance Bill bonus in the form of a new provision that deems a payment received by an individual shareholder up to 1,000 to be a capital sum rather than an income distribution, unless the shareholder elects otherwise. This means that former Eircom shareholders receiving this return of value will generally have no tax liability due to capital losses forward from that investment. Presumably this reduces significantly the administration that would be involved in chasing down small amounts of income tax from a large section of the public. Gifts to children The capital acquisitions tax code contains an exemption for normal and reasonable payments made by persons for the support, maintenance or education of their children. Currently the exemption applies without any age restriction and what is reasonable is determined by reference to the circumstances of the donor. The Bill amends this provision to restrict the benefit of this relief to payments made to minor children and to children under the age of 25 years who are in full-time education. A similar amendment will apply to an orphaned minor child. These amendments will apply from the date of passing of Finance Bill Security for certain taxes The VAT code contains a provision that allows Revenue to request security to counteract suspected phoenix businesses, i.e., where a business ceases with taxes outstanding and tries to set itself up again usually through a separate company. This provision is now being extended to all taxes.

18 What s next - Miscellaneous 18 What s next? The Finance Bill contains no measures on the taxation of receivers which has been the subject of two Department of Finance consultation processes. It is understood that a nonstatutory approach is being contemplated. There is also no sign yet of the new corporation tax rules for oil and gas activities. On 18 June 2014 the Irish Government had announced an intention to introduce a new taxation regime for petroleum exploration and production on foot of a review of Ireland s fiscal system for oil and gas conducted by consultants Wood Mackenzie. Tax Alerts on selected measures will issue over the coming weeks as the Finance Bill progresses towards enactment. It is expected that the Finance Bill will be enacted by the end of In that regard the next stage of the process at which amendments will be tabled, the Select Committee stage, is expected to commence on 18 November. At Committee Stage we anticipate legislation providing for more automatic information exchange by financial institutions. This will provide a statutory framework for the latest OECD FATCA-like initiative known as the Common Reporting Standard (CRS) which recently received European Council approval. The Minister also anticipates that the legislation providing for a 20% tax credit for water charges, as announced in Budget 2015, will be introduced at this stage.

19 Rates at a glance Income Tax Rates Universal Social Charge Pensions Stamp Duty Standard 20% Earnings Annual earnings cap 115,000 Residential property Marginal 40% 0-12,012* 1.5% Marginal rate deduction 40% First 1,000,000 1% Standard Rate Bands Single (up 1,000) 33,800 Married (up 2,000) 67,600 Married - one income (up 1,000) 42,800 Single parents (up 1,000) 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 Age credit - single (married x2) 245 Medical insurance relief max premium - adult/child 1,000 / 500 Relief for water charges 20%* *Tax relief at 20% will be provided on water charges, up to a maximum of 500 per annum per household. Income Tax age exemption Single and widowed 18,000 Married (either spouse aged 65 or over) 36,000 12,013-17, % > 17,577 and < 60,000 aged 70 and 3.5% over (medical card) 17,577-70,044 7% > 70,044 8% Self employed income > 100,000 11% *exempt if income < 12,012 PRSI Rates Employer Standard rate 10.75% Lower rate 8.5% Weekly lower rate limit 356 Self-employed PRSI 4% Minimum contribution 500 Employee PRSI 4% PRSI Weekly PRSI threshold 352 Tax free lump sum limit 200,000 Standard fund threshold 2,000,000 DIRT Deposit accounts 41%* Investment funds 41%* First time buyers DIRT relief** *No reduction in the DIRT rate or the investment fund/life assurance tax rate. **Refund of DIRT for first time buyers on savings for deposits to purchase their home up to a maximum of 20% of the purchase price. Property Charges Local Property Tax Market value < 1million 0.18% Excess value > 1 million 0.25% Capital Gains Tax Standard rate 33% Withholding tax rate 15% Annual exemption 1,270 Capital Acquisitions Tax Standard rate 33% Excess over 1,000,000 2% Non-residential property 2% Consanguinity relief (generally abolished from 1 January subject to exceptions) Corporation Tax Rates Standard Rate 12.5% Higher rate on passive income 25% 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 Preferential loan specified rates - benefit in kind Qualifying home loans 4% All other loans 13.5% Thresholds Group A 225,000 Group B 30,150 Group C 15,075

20 20 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 Sandra Dawson Financial Services, Insurance Tel: sandra.dawson@ie.ey.com David Fennell Tax Technical Services Tel: david.fennell@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 Human Capital Services Tel: jim.ryan@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@ie.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 10/14. Artwork by the BSC (Ireland) ED None (Imagery sourced from Shutterstock.com) 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