Holding Companies in Ireland

Ireland has in recent years become a destination of choice for holding companies because of its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty network, lack of CFC and thin capitalisation rules and the general ability to pay dividends free of withholding tax. The changes contained in the Finance Act 2010 (the "Act") can be seen as continuing evidence of the Irish government's commitment to attracting holding companies to Ireland.

The Irish tax issues associated with establishing an Irish holding company are reviewed under the following headings:

• establishment of an Irish holding company;
• taxation of Irish holding companies;