from Ireland February 2016 Contents Who we are Facts about Ireland Who licenses out of Ireland The Double Irish What you can still do February 2016 Who we are February 2016 TippMcKnight is a full service law firm providing legal and tax advice to businesses and private individuals ID: 578462
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International Licensingfrom Ireland
February 2016Slide2
ContentsWho we areFacts about IrelandWho licenses out of Ireland?The Double IrishWhat you can still do
February 2016Slide3
Who we areFebruary 2016
TippMcKnight is a full service law firm providing legal and tax advice to businesses and private individuals
The office is located in the heart of Dublin, in the business district
It was set up by two experienced solicitors who for many years were partners in major Irish law firmsSlide4
International approachFebruary 2016
The firm is well connected with several Irish and international trade organisations, e.g. the International Fiscal Association (IFA), the Ireland-Spain Economic Association and the Ireland-France Chamber of Commerce
Clients can be advised in English, German and French
TippMcKnight has established a wide international network of contacts and an international client baseSlide5
Recent significant dealsFebruary 2016
The acquisition of an Irish resident group of companies for € 4.5 million
Advising a major Irish public company on data protection issues
The set-up of an Irish travel company
The transfer of employees to a significant Irish client from another business
Drafted international distribution agreements for a pharmaceutical company for 55 countries
Completed Irish aspects of a significant international software acquisitionSlide6
Facts about IrelandFebruary 2016
EU Member State plus Eurozone Membership:
International airports at Dublin, Shannon, Cork, Knock and Kerry
Less than 7 hours from New York, about 1 hour from London and 2 hours from Frankfurt
Highly qualified employees available in ICT, life sciences, pharmaceuticals, new media, biotechnology and green energy
Common law legal system
Business friendly environment at all levelsSlide7
Irish TaxationFebruary 2016
12.5% Corporation Tax on trading income also applying to active licensing
25 % for passive non-trading income, e.g. rental income
The rate of Capital Gains Tax is 33%
Ireland has a wide network of Double Taxation Treaties, currently 72 treaties, of which 68 are in effect
20% Withholding Tax on royalties but not where recipient is in a treaty countries which taxes such royalties
Ireland is on the OECD white list for tax compliant jurisdictions
Various Tax Incentives for companies to choose Ireland as a business location:
Favourable Intellectual Property Regime
R&D Tax Credit System
Tax relief for Start-up companies
Attractive Holding Company RegimeSlide8
Who licenses out of Ireland ?February 2016
9 of the top 10 global software companies
9 of the top 10 pharmaceutical corporations
10 of the top 10 “born on the internet” companies
9 of the top 10 US ICT companies
The top 3 global enterprise software companies
4 of the top 5 IT service companies
15 of the top 20 global medical technology companiesSlide9
The Double IrishFebruary 2016
This tax scheme hit the headlines last year. Condemned by Obama and caused red faces in Ireland and with many multi national corporations using Ireland. The scheme is used widely in connection with cross border licensing.
Essentially the scheme in its most aggressive form involves the use of an Irish registered trading company and a second Irish registered company which is generally resident in a tax haven or qualifies as stateless.
Scheme no longer available unless the second company is tax resident in a treaty country
Existing schemes will be phased out by 2020.Slide10
What you can still doFebruary 2016
Ireland is still a good country to locate IP.
Ireland is working on the creation of a “knowledge development box” system.
No legislation has yet been published but the knowledge development box is expected to be at least as advantageous as similar schemes in other countries.Slide11
Practice AreasFebruary 2016
Banking & Finance
Corporate
Data Protection
Dispute
Resolution
Employment
Intellectual Property
Inward Investment
Life
Science
Property
TaxSlide12
Ursula Tipp is a founding partner of TippMcKnight Solicitors. She is the President of the Ireland Spain Economic Association, Director and Council Member of the Ireland France Chamber of Commerce, the Belgium Luxembourg Chamber of Commerce, the International Fiscal
Association, the Institute of Directors and the Irish - US Council. Ursula is a Lecturer in International Taxation and Cross Border Trade and Litigation at National University of Ireland
Maynooth
and regular commentator on radio and TV.
She is a regular guest speaker at legal and tax conferences in Europe and the United States.
Ursula Tipp
TippMcKnight
Solicitors
41 Fitzwilliam Place, Dublin 2
Phone:
+353 1 254 3432
Mobile: +353 86 1703405
Email
:
utipp@tipp-mcknight.com
www.tipp-mcknight.com
February 2016Slide13
Michael O’Connor is a founding partner of TippMcKnight Solicitors. Michael is a member and former Chairman of the Taxation Committee of the Law Society of Ireland and the Law Society’s representative of the Value Added Tax Subcommittee. He advises major companies on their tax and commercial issues. He is the correspondent for Ireland of the International VAT Monitor. Michael is a former Chairman of the International Fiscal Association, Ireland.Michael is the author of VAT on Property – made simple; a joint author of Stamp Duties for Business and Property and a frequent contributor of articles on taxation issues.
Michael O’Connor
TippMcKnight
Solicitors
41 Fitzwilliam Place, Dublin 2
Phone:
+353 1 254 3432
Mobile: +353 86 8592838
Email
:
moconnor@tipp-mcknight.com
www.tipp-mcknight.com
February 2016