Tax in Ireland

A&L Goodbody

A&L Goodbody has been particularly active advising on the tax aspects of M&A and corporate projects. The team also has experience in loan portfolio sales, acquisitions and securitisations, and, with the support of the firm's New York and San Francisco offices, in advising US companies on inward investments into Ireland. On the contentious side, the team handles disputes with the Irish Revenue Commissioners, tax-related state aid investigations, queries and audits. Practice head Paul Fahy specialises in corporate tax; Peter Maher has expertise in inbound investments and cross-border financings and structurings; James Somerville is noted for his strength in financial services and property-related tax; and Amelia O’Beirne, who was previously based in the firm's New York office, has extensive experience in US multinational tax planning and M&A.

Practice head(s):

Paul Fahy

Key clients

Deutsche Bank Securities Inc.

Osmotica Pharmaceuticals

Perrigo

PTSB

IPUT

Morgan Stanley

Intermediate Capital Group

Prothena

Elix Aviation Capital Limited

Smartwings

Goldman Sachs International

KN Group

NJJ

Barclays Bank plc

Ulster Bank Ireland DAC

Work highlights

  • Advised Osmotica Pharmaceuticals on the relocation of its holding company to Ireland and subsequent IPO on the Nasdaq stock exchange in October 2018.
  • Assisted Permanent tsb with the Irish law aspects of a public securitisation of a portfolio of re-performing mortgage loans through Glenbeigh 2018-1 DAC.
  • Advised Irish Continental Group on the negotiation of a bespoke new multi-faceted finance package.

Arthur Cox

Arthur Cox acts for international banks, government bodies and multinational public companies, with particular expertise in advising US-listed Irish companies. Corporate transactions, including cross-border M&A and corporate migrations, are a key area of work, as well as tax disputes and the acquisition and disposal of Irish commercial real estate portfolios. The practice has also been highly active advising on CLO, CMBS and RMBS deals. The team is led by Fintan Clancy, who has extensive experience advising on the tax aspects of corporate transactions. Caroline Devlin has expertise in advising Asian clients on establishing in Ireland; Ailish Finnerty has a notable US client base and is experienced in intangibles planning; and recently promoted partner David Kilty has expertise in international M&A and innovative finance structures.

Practice head(s):

Fintan Clancy

Key clients

Eaton Corporation plc

Blackstone GSO

Allergan plc

Ingersoll Rand

Allianz

Lone Star

Bank of America/Merrill Lynch

Ryanair

Citibank plc

Work highlights

  • Advising Eaton Corporation plc on the Irish legal and tax issues arising from the spin-off of its lighting business.
  • Acted for Shire on the Irish tax aspects of its acquisition by Takeda Pharmaceutical.
  • Advising Bank of Cyprus on Irish stamp duty matters related to a placing of €220m of Additional Tier One (AT1) capital.

Matheson

With an 'outstanding knowledge of the area', Matheson handles the full range of contentious and advisory tax matters. The team has particular expertise in advising multinational clients on reorganisations and restructurings, including IP onshoring; assisting with the tax aspects of high-profile real estate developments; Brexit planning; and transfer pricing, including transfer pricing audits and state aid matters. The practice also handles tax disputes. John Ryan focuses on corporate tax; Turlough Galvin specialises in advising international clients; Joe Duffy has particular expertise in tax controversy; Shane Hogan has experience in inward investment projects and cross-border tax planning; the 'exceptional' Gerry Thornton focuses on the financial services sector; and Catherine O’Meara has a strong multinational client base. The team was strengthened further at partner level by the arrival of Anne Harvey from William Fry and the promotions of Brian DoohanVahan Tchrakian and Philip Tully.

Practice head(s):

John Ryan; Paraic Madigan

Testimonials

The team are extremely approachable. They take the time to make sure we understand the basics as well as the more complicated tax planning. They know the history of our business intimately.

Even when they have been working long hours on particular projects, they are always courteous and ensure that they come back with an answer within the agreed timeframe.

The Matheson team have an outstanding knowledge of their area. Whilst being an exceptional law firm they have a real appreciation and understanding of commercial realities.

Gerry Thornton is simply exceptional and outstanding. His knowledge and the sound advice he provides is second to none. Gerry and his team provide a first-class service.

Strength in depth.

Kevin Smith is technically superb but has the ability to distil matters down to their essence.

Joe Duffy is a smart professional keen to meet with the client’s needs.

The commitment, knowledge and personality of this team is unique. I honestly believe you wouldn’t find a better tax team anywhere. Their knowledge is unending.

Aidan Fahy’s knowledge of all tax matters is unequalled in my view. He has a unique ability to not only motivate his own team when working on a project, but also the client.

‘Senior associate Audrey Kean’s attention to detail, approachability and subtle approach to navigating difficult conversations and problems is something to behold.

Key clients

Ballymore

Horizon Pharma plc

Nuance Communications

Oxley Holdings

Steris plc

Work highlights

  • Advised Steris plc on the Irish legal and tax aspects of re-domiciling from the UK to Ireland.
  • Advised Horizon Pharma plc on the Irish legal and tax aspects of its equity raising.
  • Assisted Nuance Communication with the Irish legal and tax aspects of the separation of its document-imaging business from its three other businesses and the subsequent onward sale.

McCann FitzGerald

Noted for its 'ability to provide concise, practical and commercial advice', the team at McCann FitzGerald has expertise in advising on tax-efficient remuneration schemes, VAT and stamp duty structures and acting for clients before the Tax Appeals Commission and the High Court in tax disputes. The team also advises on the tax aspects of corporate transactions and real estate developments, finance tax, investments into Ireland, and transfer pricing. Eleanor MacDonagh, who has extensive experience in international tax structuring through Ireland, leads the team with Alan Heuston, whose expertise includes advising on the tax implications of M&A, reorganisations and corporate migrations. Consultant Michael Ryan has experience advising on major investments projects, and senior associate Deirdre Barnicle heads the tax compliance practice.

Practice head(s):

Eleanor MacDonagh; Alan Heuston

Testimonials

McCann FitzGerald has a reputation as a leading law firm and lives up to these exceptional standards. Specifically, their strength is in personally dealing with clients, providing a framework of Irish law, and guiding their clients through the process from start to finish. Moreover, they have an immense number of connections in Ireland and beyond.

Ability to provide concise, practical and commercial advice

The experience gained by Alan Heuston as a senior executive in industry prior to returning to practice comes through in the practical, commercial advice which he provides.

Key clients

Deutsche Bank Ag London Branch

Magnetar Financial (UK) LLP

SMBC Aviation Capital Limited

Viva Aerobus

Urbeo Residential ICAV

WeWork

AXA Real Estate Investment

Managers UK Limited

Nordic Aviation Capital

Enva Group

Coillte

Pollen Street Capital

An Post

Lioncor Developments

Citibank

Arrow Global Limited

Primary Health Properties REIT

Ardstone

Irish Life Investment Managers

Electricity Supply Board

Housing Finance Agency

Work highlights

  • Advised Deutsche Bank Ag on the tax aspects of the financing of the Cardiff Lane Post Office site.
  • Assisted Nordic Aviation Capital with the tax issues of a senior unsecured private placement issuance by an Irish company within its group.
  • Advised Deutsche Bank on the tax aspects of its acquisition of the Project Lee loans, secured on a mixture of retail, commercial and residential assets, from Nama.

William Fry

In addition to advising on the tax aspects of corporate transactions, William Fry has a particular focus on foreign direct investment, transfer pricing, financial services transactions, mutual agreement procedure, tax depreciation and tax appeal cases. Noted for its 'excellent range of tax knowledge both locally and internationally', the team frequently advises on international tax matters. Practice head Martin Phelan is recommended for his 'massive knowledge and experience'. Other key contacts in the team include Sonya Manzor, who has expertise in inward investment, corporate reorganisations and M&A; Ted McGrath, who specialises in advising clients in the financial services sector; the 'technically strong and practical' Shane Wallace; and Brian Duffy, who has particular expertise in tax controversy. The 'top-drawer' Declan Lavelle and 'highly responsive' Rachel Fox, who has experience in capital markets transactions, were promoted to partner.

Practice head(s):

Martin Phelan

Testimonials

The team is professional, well informed and forward thinking.

Martin Phelan is the top tax adviser in Ireland. Martin’s straight-talking, honest approach ensures that he is a go-to individual for any advice. Martin is an incredible resource.

Declan Lavelle is top drawer, maintaining a friendly approach coupled with advice of the highest quality.

Responsive, partner-led tax practice issuing practical advice.

Shane Wallace is responsive, user-friendly, technically strong and practical.

Martin Phelan has massive knowledge and experience.

William Fry’s tax team are responsive and helpful, and we fully trust the advice that we receive.

Rachel Fox is enormously helpful. She provides detailed, thorough advice and is happy to talk through tax issues on the phone. She is highly responsive and gives enough context to allow us to anticipate future tax issues before they arise.

We turn first to Martin Phelan and Ted McGrath at William Fry.

Knowledge, experience, professionalism and the ability to apply lateral thinking and multi solutions.

Very responsive, with an excellent range of tax knowledge both locally and internationally.

Declan Lavelle and Martin Phelan are the standout partners and both have a very detailed grasp of our business operations. Their advice transcends tax and law and helps us make better and more informed business decisions. They are our most valued business partners.

Good international network.

Martin Phelan and Brian Duffy are commercial and responsive.

Key clients

DCC PLC

Smurfit Kappa

Afilias

Inditex SA

Linde AG

Silicon & Software Systems Limited

State Street Corporation

U+I Plc

WisdomTree Investments

Mercer Global Investments Europe

Smartbox

Work highlights

  • Advised Linde AG on the Irish tax aspects of its merger with Praxair and listing on the New York and Frankfurt Stock Exchange.
  • Advised Axa Life Europe on the tax aspects of its acquisition by private equity firm Cinven.
  • Advised Uniphar plc on the tax aspects of its acquisition of the healthcare distribution business of Sisk Group.

Eversheds Sutherland

Eversheds Sutherland's 'strong' team is particularly experienced in advising large domestic and international corporations and financial institutions, assisting with the tax aspects of establishing operations in Ireland and cross-border restructurings and M&A. It also advises on internal reorganisations, including the onshoring of IP, high-profile Irish investment projects, indirect tax, transfer pricing and tax disputes. Key sectors include renewable energy, real estate and financial services. 'Excellent' practice head Alan Connell focuses on advising international clients, with particular expertise in inward investment and restructuring projects in Ireland.

Practice head(s):

Alan Connell

Testimonials

Alan Connell is very knowledgeable, client-focused, and practical in his approach. It is a pleasure to work with him.

The advice provided was comprehensive, practical and delivered in a manner that was easy to comprehend.

Solicitor Emma Hartnett provided a personal and personable service.

Eversheds deliver what we need articulately, quickly, and responsively.

Alan Connell is an excellent partner who makes complex issues clear. We appreciate him for his strategy and insights.

Emma Hartnett is an excellent lawyer. She explains things to us well, and we value her for her strategic insights and availability.

Strong team with a great understanding of the client’s needs and the subject matter

Alan Connell and his team have a great focus and always come prepared to help solve the issues.

Key clients

Allied Irish Banks plc

American Express

Aviva

EirGrid plc

Enercon GmbH

Fiserv

HID Global

Independent News & Media

Kraft Heinz

Lime Energy

Microsoft

Musgrave Group

Roche Diabetes

Screwfix

Symantec Corporation

Work highlights

  • Advised Star Capital Investments Limited on the tax aspects of its acquisition of ASL Aviation.
  • Advised Ontario Teachers’ Pension Plan, from a tax perspective, on the acquisition of Giraffe Childcare through its investment vehicle Busy Bees.
  • Advised Payzone Ireland on the tax aspects of its takeover by Allied Irish Banks and First Data.

Maples Group

Maples Group specialises in tax matters relating to internationally focused investment fund, investment platform and financing transactions, providing cross-border advice with the assistance of the firm's international offices. The team also advises on tax issues surrounding the formation and operation of Irish-based regulated funds, the acquisition of Irish real estate portfolios, and high-profile domestic M&As and restructurings. On the contentious side, the team handles audits and compliance interventions. Practice head Andrew Quinn counts domestic and international companies, investment funds and banks among his clients, while William Fogarty - 'one of the best tax advisers in Europe' - has particular expertise in Irish property and financing structures and new partner Lynn Cramer specialises in advising investment funds on indirect tax issues.

Practice head(s):

Andrew Quinn

Testimonials

The ability to provide a fully integrated service from legal advice, tax advice and the funds business places Maples in a unique position in the Irish market.

Will Fogarty is our primary contact for all matters relating to tax. He proved, again and again, his ability to explain difficult tax structuring issues and provide the appropriate structures for our investments.

Will Fogarty is one of the best tax advisers I have come across in Europe. He is strong technically but very practical and commercial in his advice.

Work highlights

  • Advised on the Irish tax issues associated with the formation and marketing of an Irish residential-focused fund.
  • Assisted with cross-border tax issues and with dealing with recognition of and indemnification in respect of deferred tax assets in the Solvency II Directive.
  • Advising an asset management company on the acquisition, management and disposal of properties in its Irish portfolio.

Mason Hayes & Curran LLP

Noted for its 'responsiveness and technical strength', Mason Hayes & Curran LLP counts leading domestic and international corporates and financial institutions among its clients, with particular expertise in advising technology multinationals on the tax implications of establishing operations in Ireland. Other areas of expertise include assisting with major group reorganisations involving Ireland; securitisation advice on the use of Irish SPVs; and real estate structuring. Niamh Keogh has significant experience advising on the use of Irish regulated fund structures and securitisation vehicles, and ‘incredibly responsive and detail-oriented’ senior associate Eilís Griffin is also recommended. Maura Dineen departed for DLA Piper and former practice head John Gulliver also left the firm. Niamh Caffrey was a new arrival from Eversheds Sutherland.

Practice head(s):

John Gulliver

Testimonials

The tax team is responsive, technically good (even in niche areas) and helpful.

The qualities we value are their responsiveness and technical strength.

Niamh Keogh is keen to help and delivers once instructed, often in very tight timescales, and is always very pleasant to deal with.

Mason Hayes & Curran’s team has an expertise and depth of knowledge that allows them to quickly respond to questions and inquires. This allows for an efficient working relationship that helps to keep projects moving swiftly.

Senior associate Eilís Griffin is incredibly responsive and detail oriented. Her ability to make complex issues easy to understand is very helpful in crafting appropriate solutions.

Key clients

Blackhawk Network Holdings Inc

Fane Valley Co-Operative Society Limited

Allied Irish Banks Plc

Irish Residential Properties REIT plc

Irish Life

Renault

SSE Renewables Ireland Limited

Broadridge Financial Solutions

WeWork

Work highlights

  • Advised Blackhawk Network Holdings on the tax aspects of its acquisition of TSC Ventures.
  • Advised Irish Residential Properties REIT plc on the tax aspects of its agreement to acquire shares in Bayvan, a subsidiary of Dalata Hotel Group plc, from DHGL.
  • Advised Fane Valley Co-Operative Society on the tax issues of its acquisition of Silver Hill Foods.

Walkers

Walkers' 'excellent' team has been particularly active advising on capital markets transactions, with expertise in CLO and CMBS transactions and distressed loan portfolio acquisitions. Other areas of strength include real estate tax structuring; assisting investment fund clients with restructuring their existing portfolios and establishing new loan origination funds; and advising on the tax aspects of domestic and international M&A transactions and corporate migrations to Ireland. 'Exceptional' practice head Jonathan Sheehan has extensive experience across financial, corporate and real estate transactions, while the 'excellent' Aisling Burke advises on tax structuring, inward investment and contentious tax matters, and of counsel Eimear Burbridge has particular expertise in the CLO and asset finance space.

Practice head(s):

Jonathan Sheehan

Testimonials

The Walkers tax team in Ireland is excellent. The team is very responsive to our queries and provides solid deliverables. We have a great working relationship.

Jonathan Sheehan is fantastic to work with. He is very responsive to queries and commercially focused in his advice. He has a deep understanding of the Irish tax landscape.

Jonathan Sheehan is an exceptional tax lawyer. He is very technical but his grasp of the technical detail enables him to be very commercially minded with structuring and executing transactions.

Aisling Burke is an excellent tax practitioner.

Key clients

Tramontana Asset Management

Bench Walk Advisors, LLC

Bardin Hill (formerly Halcyon Loan Advisors (UK) LLP)

Santander Consumer Finance

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

Bain Capital

Banco Santander/Santander Consumer Finance/Santander UK

Bank of America Merrill Lynch (BAML)

Onex Capital Partners

Work highlights

  • Advised Tramontana Asset Management as lead arranger on the Irishtax law aspects of the establishment of an innovative asset-repackaging secured-note programme using an Irish section 110 SPV as issuer.
  • Advised Lloyds Bank on the Irish legal and tax aspects of a balance sheet commercial real estate synthetic securitisation involving an Irish section 110 issuer, Wetherby II Securities DAC.
  • Advised Bardin Hill on three European CLO issuances.

Philip Lee

Philip Lee has experience advising on the tax aspects of M&A transactions, group restructurings and property transactions. The team also advises on personal and corporate tax planning, insolvency and probate issues, and tax disputes. Practice head Amanda-Jayne Comyn, who joined the firm in 2018 from Grant Thornton, advises on the tax implications of corporate and real estate transactions and handles tax litigation.

Practice head(s):

Amanda-Jayne Comyn

Key clients

Corrib Oil Company Limited

Michael Ryan

Scottish Power Renewables Limited

Airbnb Unlimited Company

KonnectAgain Limited

Work highlights

  • Advised Corrib Oil Company on the tax aspects of a group restructuring.
  • Assisted a property developer with the tax aspects of two major residential property development structures involving five separate UK investors.
  • Advised Scottish Power Renewables on stamp duty and capital gains tax matters.

Ronan Daly Jermyn

Ronan Daly Jermyn has been particularly active advising on the tax aspects of significant corporate and property transactions, with particular expertise in the hotels and leisure, and healthcare sectors. The team is also noted for its tax appeals practice, handling Revenue disputes and tax investigations, and for advising businesses and individuals on tax-efficient succession planning. John Cuddigan leads the team from the Cork office and has extensive experience in direct and indirect taxation, corporate restructuring and property transactions, while Mark Barrett regularly advises international clients on establishing operations in Ireland.

Practice head(s):

John Cuddigan

Testimonials

They take the time to fully understand our business requirements.

The team stand out for their professionalism and their work ethic. John Cuddigan is the partner I would like to mention.

Key clients

Abtran Group

Primacy Healthcare 21 Holdings

Moore Stephens

AAI Holdings Limited

O’Callaghan Properties Limited

Bon Secours Health Systems

Premier Recruitment (International) Limited (Morgan McKinley)

iNua Hospitality PLC

Denis O’Brien (Developments) Limited

Saleel Limited

Work highlights

  • Advised iNua Hospitality plc on the tax aspects of a number of transactions, including the establishment of a new group holding structure.
  • Advised Morgan McKinley on the tax aspects of the restructuring of the group equity structure.