Tax in Ireland

A&L Goodbody LLP

A&L Goodbody LLP has significant experience in the tax aspects of high-profile M&A, financial and real estate transactions, and has also been active in contentious tax matters. Transfer pricing matters, often involving advice on IP onshoring, and inward investment projects are also key areas of expertise. Corporate tax specialist Paul Fahy leads the team, which also includes Peter Maher, who has particular expertise in inbound investments and cross-border financing, Amelia O’Beirne, who has significant experience in the US market, and James Somerville, who has particular strength in financial services and property-related tax.

Practice head(s):

Paul Fahy

Other key lawyers:

Peter Maher; James Somerville; Amelia O’Beirne; Philip McQueston

Key clients

Perrigo Company plc

Goldman Sachs

Bank of Ireland

AIB Group plc

Societe Generale

Endo International plc

The Stars Group

Iterum Therapeutics plc

BNP Paribas

Work highlights

  • Advised Ethoca on the tax elements of its acquisition by Mastercard.
  • Advised Investec on the tax aspects of the sale of its Irish wealth management business by way of the sale of the entire issued share capital of Investec Capital & Investments (Ireland) Ltd to Brewin Dolphin.
  • Advised the Governor and Company of the Bank of Ireland, Bank of Ireland Mortgage Bank and Mulcair Securities DAC on the tax issues involved in the securitisation of a portfolio comprised entirely of buy-to-let residential mortgage loans.

Arthur Cox

Arthur Cox has been highly active in advising on the tax aspects of significant corporate and financial transactions, handling both domestic and cross-border matters. The team also advises on tax matters in the fintech space, the migration of commodities platforms to Ireland, and the acquisition and disposal of Irish real estate portfolios, and continues to grow its tax controversy practice. Fintan Clancy leads the practice, which counts numerous multinationals, including many US-listed Irish companies, among its clients. Caroline Devlin, Ailish Finnerty and David Kilty, who has particular expertise in innovative financial structures, are also key contacts.

Practice head(s):

Fintan Clancy

Other key lawyers:

Caroline Devlin; Ailish Finnerty; David Kilty

Key clients

Eaton Corporation plc

Blackstone GSO

Allergan plc

Trane Technologies

Allianz

Abbey International Finance

Bank of America/Merrill Lynch

Citibank plc

CRH plc

Mallinckrodt Pharmaceuticals

Medtronic

Aviator

Work highlights

  • Advised Ingersoll Rand plc (now Trane Technologies) on the tax elements of the spin-off of its industrial business and merger with Gardner Denver Holdings Inc, creating a company valued at around $15bn.
  • Advised Aon plc on the tax aspects of its all-share combination with Willis Towers Watson to create the world’s largest insurance broker.
  • Assisting various clients with the tax aspects of Russian loan participation note structures issued through Irish finance vehicles.

Matheson

Matheson's 'practical and responsive' team has wide-ranging tax expertise, with particular strength in the tax aspects of internal reorganisations and restructurings, tax matters in the real estate sector, and transfer pricing. It is also highly active in large-scale tax disputes. Clients include numerous international corporations and financial institutions. Among the key contacts in the sizeable team are practice head John Ryan; corporate tax expert Joe Duffy; Turlough Galvin; Shane Hogan; Catherine O’Meara, who has a strong client base of multinationals headquartered in Ireland; Gerry Thornton; indirect taxes specialist Matthew Broadstock; and senior associate Tomás Bailey.

Practice head(s):

John Ryan

Other key lawyers:

Turlough Galvin; Shane Hogan; Greg Lockhart; Catherine O’Meara; Gerry Thornton; Joe Duffy; Aidan Fahy; Matthew Broadstock; Brian Doohan; Vahan Tchrakian; Philip Tully; Tomás Bailey

Testimonials

‘A great firm that understands our businesses and provides practical advice and the tax expertise and guidance to run our businesses.’

‘They are very practical, very responsive, provide great solutions and are always available at short notice to support our business.’

‘The firm distinguishes itself from its peers by being consistently responsive, even across time zones, and providing concise and direct advice with a good appreciation for commercial concerns as well as legal ones.’

‘The individuals who I have worked with have set themselves apart by being responsive, concise and pragmatic and having a solid appreciation for commercial considerations. I have worked extensively with Gerry Thornton and am highly satisfied with the service provided.’

‘Joe Duffy delivers exceptional service and is a great person to deal with. He has helped us on numerous occasions with to-the-point and swift feedback on tax matters.’

‘They have consistently been able to recommend innovative tax solutions to address our needs and have readily adapted to complex and unique legal structures.’

Key clients

AbbVie

Broadcom

Gardner Denver

Grifols SA

Mergon Group

Symantec

syncreon

Weatherford International plc

Willis Towers Watson

Work highlights

  • Advised AbbVie on the Irish tax aspects of its acquisition of Allergan plc.
  • Advised on the tax elements of the global restructuring of Weatherford’s debt and its corporate reorganisation.
  • Advised Willis Towers Watson PLC on the tax aspects of its $80bn all-stock combination with Aon PLC.

William Fry

The 'practical and business-oriented' tax practice at William Fry has extensive experience in the tax aspects of global M&A transactions, and also has dedicated teams focusing on foreign direct investment, transfer pricing and financial services tax. Representing clients in tax appeal cases is also a particular area of strength. Sonya Manzor, who has notable expertise in the tax structuring of inward investment and corporate transactions, leads the team following Martin Phelan's departure for Simmons & Simmons. Ted McGrath, Brian Duffy, Declan Lavelle and Rachel Fox, who is particularly experienced in M&A tax, are also recommended.

Practice head(s):

Sonya Manzor

Other key lawyers:

Ted McGrath; Brian Duffy; Rachel Fox; Declan Lavelle

Testimonials

‘Declan Lavelle is very detail-oriented, proactive and responsive. He has very strong technical skills and the ability to effectively communicate complex tax matters in a straightforward manner, which is beneficial when discussing matters with non-tax personnel.’

‘The William Fry tax team work wonderfully as a team. They genuinely seek to form a partnership with their clients, working hand-in-hand with legal counsel and management to achieve the desired business goals. The tax team are very practical and business oriented, seeking solutions that of course meet the highest legal technical standard, but doing so in a way that clients can understand and implement over the long term. Having worked with the WF tax team primarily in resolving international tax and investment matters, I have seen the careful attention to detail in working through solutions that will not only meet Irish legal requirements, but those in other operating jurisdictions.’

‘Having worked extensively with Sonya Manzor, Declan Lavelle and Rachel Fox, I can say that each of them fully embody the William Fry values. Each of these individuals deliver practical legal advice, provided in a timely fashion and with the highest attention to quality. They are quick to respond and go above and beyond in delivering for their clients, tending to complex matters at all times of the day and the year.’

‘The William Fry tax team is uniquely qualified in advising with respect to Irish tax issues in the cross-border context, both inbound and outbound. The team has broad experience across a number of sectors. Their client service and responsiveness is impressive. Sonya Manzor and Rachel Fox are excellent, both substantively and from a client service perspective.’

‘What makes this team unique is that, in addition to their strong tax technical knowledge, the William Fry tax team are very commercial and practical in their approach.

‘Sonya Manzor leads a very strong team at William Fry. I have worked with Sonya for several years and have always found her and the members of the wider William Fry team to be excellent. Sonya and her team provide superb client service to us. I would want Sonya to be on my side in negotiations of an M&A transaction.’

‘I worked closely with Rachel Fox on a transaction earlier this year. Rachel was very knowledgeable about the relevant tax technical issues, but also able to give very practical advice on the related structuring and legal matters. She was available to deal with queries at short notice and provided excellent client service throughout the transaction process. Rachel was able to communicate technical tax and legal matters to the commercial teams easily, and also worked well with the other legal teams involved to get the deal done.’

‘Ted McGrath is the best in the industry. He is practical and pragmatic and makes the complex simple. His unique skills and professionalism differentiate William Fry in the marketplace.’

Key clients

DCC PLC

Smurfit Kappa

Afilias

Inditex SA

Linde AG

Silicon & Software Systems Limited

State Street Corporation

U+I Plc

WisdomTree Investments

Ardagh Packaging Group

Smartbox

Accenture

Paine Schwartz Partners

Clanwilliam

Phillips 66

Work highlights

  • Providing ongoing tax advice to Smurfit Kappa on a range of matters, including its recent €750m bond issuance and subsequent redemption of notes worth €750m which were due to mature in 2020 and 2021.
  • Acted as the Irish tax advisers to Accenture on its acquisition of Symantec’s cyber security services business from Broadcom, Inc. and currently advising on the post-acquisition integration, including IP structuring.
  • Acted as tax advisers to AXA IM-Real Assets and BCP Capital on the acquisition of La Touche House in the IFSC.

Eversheds Sutherland

Eversheds Sutherland bolstered its 'commercial, responsive and knowledgable' tax team with the arrivals of Tim Kiely, who brings significant expertise in corporate tax, from BNP Paribas in July 2020 and senior associate Melissa Daly from McCann FitzGerald in May 2020. The team counts large domestic and international corporations and financial institutions among its clients, and is particularly experienced in advising on the tax aspects of establishing holding company structures in Ireland, cross-border M&A transactions, and internal reorganisations and restructurings. Newly appointed managing partner Alan Connell leads the practice and is highly experienced in large-scale inward investment and restructuring projects.

Practice head(s):

Alan Connell

Other key lawyers:

Tim Kiely; Melissa Daly; Robert Dever

Testimonials

‘Expert tax advice which is business focused, clear and succinct.’

‘Alan Connell is very clear in the advice he provides and can be trusted to have his client’s best interests at heart.’

‘Very commercial, responsive and knowledgeable.’

‘The firm has very qualified people in their respective fields who can provide expert advice and analysis quickly to the client. They also have the ability to reach across various jurisdictions to obtain the correct answer for the client on a consistent basis. They also take the time to make sure they explain properly the options for the client.’

‘Alan Connell’s advice is always complete when we receive it and is always well thought out. We understand the tax ramifications from Alan’s work as well as the cost analysis.’

‘The team are responsive and supportive – they take the time to fully understand the issue. When time has been critical they have suggested ways in which they could give the business additional comfort.’

‘The team always provide excellent tax advice and breaks it down into manageable and understandable pieces for people such as our HR team, who do not have a background in tax. The ability to build relationships with clients and have a very friendly and approachable manner most definitely encourages our business to contact Eversheds for help and support when required. I don’t think this ability can be underestimated.’

‘Robert Dever provides us with excellent advice and support. He is always responsive to our requests for assistance. On numerous occasions, Robert has taken the time to explain very detailed and complex tax items to us, so that we understand the reason for his decision or advice. This is extremely helpful to us. We would view Robert as a trusted business partner and he always provides us with correct, clear and excellent tax advice.’

Key clients

Allied Irish Banks plc

Colliers International

Dachser

Microsoft

Reckitt Benckiser

Rubix Group International

Specialist Risk Investments

SPX

Stena Line

T5 Data Centers

Work highlights

  • Advised Sovereign Capital Partners on the tax aspects of the sale of the Arachas group to Madison Dearborn and HPS Investment Partners, the acquisition of O’Driscoll O’Neill (Group) Limited, and the sale of Eugene Corrigan Insurances.
  • Advised HSBC Bank plc on the tax elements of the first-ever green loan principles-compliant facility in Ireland.
  • Advised Dublin Port Company on the tax issues relating to a bond issuance and its first major fundraising project.

Maples Group

Maples Group is particularly active in advising international financial services clients, including investment banks, private equity firms and hedge funds, on Irish tax matters. The team is experienced in the tax aspects of corporate and structured finance transactions - with specialist expertise in CLO transactions - VAT and direct tax issues relating to investment funds, and real estate and personal tax. Andrew Quinn leads the practice; William Fogarty has 'exceptional expertise' in tax matters including Irish property and financing structures and Revenue disputes; and Lynn Cramer is particularly experienced in tax planning for international clients.

Practice head(s):

Andrew Quinn

Other key lawyers:

William Fogarty; Lynn Cramer

Testimonials

‘Will Fogarty provides exceptional expertise on tax matters coupled with an excellent commercial focus. Excellent availability and engagement and will proactively contact us with matters to bring to our attention.’

Key clients

HPS Partners

Apollo Global Mangement

Blackstone/GSO

Morgan Stanley

Marathon Asset Management

Allied Irish Bank plc

Bain Capital

Avestus Capital Partners

Waterfall Asset Management

Oaktree Capital

Guggenheim Investment Partners

Cardinal Capital Group

Work highlights

  • Acted as Irish tax and legal adviser to LCPR Senior Secured Financing Designated Activity Company in connection with Liberty Cablevision of Puerto Rico’s $1.2bn offering of 6.750% senior secured notes due 2027.
  • Advised Luminus Management LLC on its participation in the recapitalisation transaction of a Canadian corporation, Delphi Energy Corp.
  • Advised Small Business Origination Loan Trust 2019-2 Designated Activity Company on tax matters.

Mason Hayes & Curran LLP

Highlighted for its 'subject matter excellence', Mason Hayes & Curran LLP advises on the tax elements of M&A and structured finance transactions, group reorganisations, and IP onshoring projects. The team is particularly experienced in advising technology, pharmaceutical, financial services and energy sector clients, and in assisting multinationals with the tax issues relating to establishing operations in Ireland. Niamh Caffrey, who has significant expertise in real estate tax and cross-border transactions, leads the team with Niamh Keogh, who is experienced in inward investment. Senior associate Eilís Griffin is also recommended.

Practice head(s):

Niamh Caffrey; Niamh Keogh

Other key lawyers:

Eilís Griffin

Testimonials

‘I was very impressed by Mason Hayes & Curran in general and by their levels of client service and partner-led delivery. I expect subject matter excellence but what most impressed me was their commitment, perseverance and practical advice. Niamh Keogh provided commercial, risk-based advice crucial to the success of the transaction we were working on.’

‘Eilís Griffin is a very capable and experienced adviser and admirably supported us on diligence and structuring. Both she and Niamh Keogh were charming and had excellent client skills.’

‘Niamh Caffrey is very competent, easy to deal with, diligent and cooperative. She understands the global picture of the transaction and the constraints from foreign jurisdictions and always focuses on finding a pragmatic solution to make the deal go through.

‘We have found the MHC team to have great tax expertise in the area of financial services and they are very proactive at maintaining senior government relationships so that complex questions and issues can be addressed very quickly.’

‘Niamh Caffrey is the best tax lawyer that we have worked with when it comes to explaining complex tax law and developing a plan on how we can adapt our business model to ensure compliance with her advice.’

‘One of the team’s key strengths is their responsiveness and their ability to quickly provide input on ad hoc tax questions. Niamh Caffrey and Niamh Keogh have been particularly helpful in a large number of projects.’

‘This team respond swiftly. This more than anything else is vital for in-house counsel. Niamh Caffrey always goes above and beyond to assist her clients. No matter what Niamh has on, she will always respond to let you know when she can get back to you to give you a practical steer on what steps to take. This is invaluable.’

Niamh Keogh is an excellent tax specialist. She is very user-friendly, knowledgeable and cuts to the heart of the issue.’

Key clients

Flexfunds Ltd

Kennedy Wilson

Appian Investments Limited

Hauck & Aufhäuser Privatbankiers AG

Work highlights

  • Advised Kennedy Wilson on the Irish tax considerations relating to the sale of the Portmarnock Hotel and Golf Links to the Northland Properties Group.
  • Advised Appian Investments Limited on the application of Ireland’s amended tax regime for Irish real estate funds to investors in the fund and consequent withholding and tax reporting requirements of the fund.
  • Advised Hauck & Aufhäuser Privatbankiers AG on the tax elements of its acquisition of Crossroad Capital Management Limited.

McCann FitzGerald

The 'highly technical and commercial' team at McCann FitzGerald has particular expertise in the tax aspects of financial, corporate and real estate transactions. The practice also advises on tax compliance and inward investments in Ireland, and has a tax dispute resolution group. Eleanor MacDonagh, who is noted for her strong real estate tax practice and expertise in international tax structuring, leads the team with Alan Heuston, who has a specialism in tax issues in the betting and gaming sector. Head of compliance services Deirdre Barnicle is also noted.

Practice head(s):

Eleanor MacDonagh; Alan Heuston

Other key lawyers:

Deirdre Barnicle

Testimonials

‘Alan Heuston specialises in Irish tax law, and has extensive experience in guiding teams through proper compliance with Irish law. His expertise provides us with a framework that allows us to operate within the guidelines and helps us avoid potential pitfalls that others have experienced. His work is truly outstanding. He is sharp, experienced and well versed in dealing with us as a client.’

‘Alan Heuston is perhaps the best attorney that we have encountered in Ireland and abroad. His work is flawless in regards to tax. He ensures that our company can create the right amount of value and savings by following the spirit and letter of the law. We value his knowledge of the law, his expertise in explaining complex tax code to our team, and his personal attitude with the clients. Our experience has been A+. I without reservation give Alan Heuston my highest recommendation. He is in the top 1% of solicitors.’

‘The practice is unique in that each assignment is individually managed and given one-to-one personal attention.’

‘The individuals are readily approachable and highly technical and commercial.’

Key clients

Aufbau Medical Innovations Limited

Activate Capital Limited

AerCap

AIB

Aircastle

Ardstone

Arrow Global Limited

AXA Real Estate Investment Managers UK Limited

Bank of America NT&SA

Bank of Ireland

Bank of Tokyo Mitsubishi

Bankinter S.A.

BBAM Aviation Services Limited

Bbva Ireland Plc

BCI Finance Limited

Blackstone Mortgage Trust, Inc

Broadhaven Credit Partners

Brookfield Renewables

BWG Foods

Calypso AI Limited

Capitalflow

CarTrawler Group

Central Bank of Ireland

Citibank

Coillte

Conexim Advisors Limited

Cortes NP Acquisition Corporation

Deutsche Bank Ag London Branch

Dunport Capital Management

Electricity Supply Board

Elm Corporate Credit DAC

Emerge Capital Partners

Enva Group

European Commission

Evolution Gaming Limited

Faber & Faber

Fly Leasing Limited

FPG Amentum

Generali Insurance

Global Student Accommodation

Goldman Sachs

Greencoat

Haitong UniTrust International Leasing

Harvest Warehouse & CLO Platform

Housing Finance Agency

Huuuge Games

Ig Group Plc

IMMAC Holding AG

Investec Bank (UK) Limited

Irish Life Investment Managers

Irish Residential Properties REIT

Jones Engineering (Holdings) Limited

Karv Developments Limited

KBC Asset Management NV

Kosmos Management LLC

LeoVegas Gaming Plc

Lioncor Developments

Magnetar Financial (UK) LLP

Mapletree Investments

Mitsubishi Electric Europe Bv

Monument Re

MUFG Bank Ltd

National Lottery

Nordic Aviation Capital

Oaktree Capital

Paddy Power Betfair (now known as Flutter Entertainment Plc)

Pepper Finance Corporation (Ireland) DAC

Pollen Street Capital

Primary Health Properties REIT

Probe Investments Limited

Prudential Plc

Rabobank Dubln

Security Risk Advisors International Limited

SMBC Aviation Capital Limited

Susquehanna International Group Limited

The Barry Family (the shareholders of Dubray Books Limited)

UBS Investment Bank

Ulster Bank Ireland Limited

Urbeo Residential ICAV

Viva Aerobus

Vodafone Ireland Limited

WeWork

William Hill

Willis Towers Watson plc

Work Human

Work highlights

  • Advised Blackstone Mortgage Trust, Inc. on all tax aspects connected with its provision of €1.34bn of acquisition funding to Henderson Park in respect of the acquisition of Green REIT plc.
  • Advising Irish Life on the tax aspects of transactions including the acquisitions of Conexim Advisors Limited, Acumen and Trust, and APT Workplace Pensions and APT Wealth Management.
  • Advised Maples Tree Investments on the tax aspects of its cross-border investment in Irish real estate via the forward purchase of the Sorting Office in Dublin from Marlet.

Walkers

Walkers' 'extremely responsive and technically on the ball' tax team advises on a wide range of corporate, real estate, investment fund and financial transactions (particularly in the CLO space), as well as providing tax compliance advice through its corporate services business, Walkers Professional Services. The team has a strong international client base, particularly in the financial services sector. Practice head Jonathan Sheehan and Aisling Burke are highly experienced in corporate, finance and real estate tax, while of counsel Eimear Burbridge has particular expertise in the CLO and asset finance areas.

Practice head(s):

Jonathan Sheehan

Other key lawyers:

Aisling Burke; Eimear Burbridge

Testimonials

‘The real estate tax team is exceptional. They provide clear, articulate and highly commercial advice on complex cross-border transactions and restructurings.’

‘Jonathan Sheehan is exceptional both in his technical knowledge and his commercial approach. Aisling Burke is a superb lawyer who is extremely articulate and very responsive.’

‘Jonathan Sheehan has great technical knowledge. He is also very user-friendly and commercial.’

‘Walkers’ tax team has a specialty in capital markets and regulated entities. The team is professional, responsive, commercial and a pleasure to work with.’

‘Jonathan Sheehan has great insight into Irish tax trends and developments. He is very responsive and provides excellent deliverables, and works well with other Walkers departments to provide consolidated advice. Eimear Burbridge, has great availability and turns quality deliverables around in an efficient manner.’

‘Jonathan Sheehan was a standout in my most recent experience with Walkers. His knowledge and advice was second to none, as was his ability to absorb a problem and provide an eloquent solution. It should also be noted that his work ethic and client management were perfectly correlated to his technical ability.’

‘Extremely responsive, technically on the ball, pragmatic commercially and very pleasant to deal with.’

Jonathan Sheehan is very good to work with and extremely responsive and helpful.’

Key clients

Tramontana Asset Management

Bardin Hill (formerly Halcyon Capital Management)

KTB Asset Management

UnipolSai Assicurazioni S.p.A.

Goldman Sachs

BNP Paribas Asset Management UK Limited

Lloyds Bank plc

Man Group plc / Man GPM Aalto

UniCredit Bank AG

Onex Capital Partners

Banco Santander/ Santander Consumer Finance/ Santander UK

Bank of America Merrill Lynch (BAML)

DTZ Investors

Certa Insurance Partners

Accunia Credit Management Fondsmæglerselskab A/S

Work highlights

  • Advised KTB Investment & Securities together with KTB Asset Management on the tax aspects of an off-market acquisition by way of share purchase of Ireland’s largest building, the Tesco Distribution Centre in Donabate, for approximately €160m.
  • Acted as Irish legal and tax counsel to Bank of Scotland plc on the synthetic securitisation of UK mortgage loans through Syon 2019 Designated Activity Company.
  • Acted as Irish legal and tax counsel to Goldman Sachs International Bank on the first green bond European CMBS issuance for in excess of €186m – River Green Finance 2020 DAC.

Ronan Daly Jermyn

The 'knowledgeable, efficient and trustworthy' team at Ronan Daly Jermyn is experienced in the tax structuring of corporate and real estate transactions, particularly in the healthcare sector, as well as providing tax advice on succession planning and wealth management to a number of high-net-worth individuals. The 'excellent' John Cuddigan leads the team, which also includes Mark Barrett and Eoin Tobin, who heads the private client services practice.

Practice head(s):

John Cuddigan

Other key lawyers:

Mark Barrett; Eoin Tobin

Testimonials

‘They are very pragmatic in approach.’

‘John Cuddigan is very commercial, very pragmatic and very user friendly.’

‘Knowledgeable, efficient, trustworthy.’

‘Eoin Tobin is a highly reliable and trustworthy individual. He has the ability to explain things in a very clear and concise manner. He is extremely personable and I would have great faith in his advice.’

‘Our experiences and interactions with Ronan Daly Jermyn have always been exceptional. The firm has a strong cohort of talented people who not only have a broad understanding of the sector, but also a really good business sense and work hard to fully understand the rationale behind our business decisions.’

‘John Cuddigan is an excellent solicitor, very personable, with a commercial head on his shoulders. He has a wealth of knowledge and is always focused on the big picture for our business.’

‘Very competent team with good communication skills.’

‘Eoin Tobin has good tax skills, Mark Barrett understands how the Revenue view issues, and John Cuddigan has extensive knowledge.’

Key clients

Bon Secours Health System

West Cork Distillers

iNua Hospitality PLC

Musgrave Retail Partners

Crest Solutions Limited

Abtran Group

Geaney Property Group

AAI Holdings Group

Hovione Limited

Work highlights

  • Advised Bon Secours Health System on the tax aspects of the merger between Bon Secours Health System (BSHS) and Bon Secours Mercy Health (BSMH) in the US.
  • Advised West Cork Distillers on the tax issues relating to the exit of a substantial shareholder.
  • Advised Simply Blue Energy Group on tax issues relating to its joint venture with Total.