The opportunity of the Europe's lowest corporate tax environment
The securing of the 12,5% rate of Corporation Tax will not require any submissions or approvals from Irish Government Agencies or Tax Authorities. The maintenance of this rate will however be subject to Corporate entities in Ireland carrying on a definable trade and satisfyng transfer pricing rules with foreign jurisdictions, if relevant.
Demonstration of real presence in Ireland will be essential.
The types of services which are likely to be attracted here with the advent of lower corporate Tax rates may include:
Commissions/margins could be earned in respect of sales, provided evidence can be produced that sales are concluded in Ireland through the Irish company and that sufficient expertise exists in Ireland in order to conclude sales.
Raw materials can be routed through an Irish purchasing company. Again, it will be necessary to demonstrate that the Irish Company has the required expertise in Ireland.
It may be appropriate to estabilish an Irish research company wich can charge the group for the its services.
It may be appropriate to estabilish a treasury unit in Ireland. The Irish banking system is well used to the estabilishment of such units because of its experience with the IFSC.