Irish Holding Company

In 2004 the Irish Government introduced a participation exemption regime in respect of the disposal of subsidiaries. Since then Irish tax law applicable to holding companies of a trading group has been expanded and developed to make Ireland a very attractive location for establishing holding companies.

In choosing a jurisdiction to locate a holding company essential requirements include:

• no additional tax on dividend income;

• no capital gains tax on disposal of subsidiaries;

• no outward bound withholding taxes on dividends or interest;

• an interest deduction for borrowings used to finance acquisitions;

• no anti-abuse legislation such as controlled foreign corporation (CFC), transfer pricing or thin capitalisation; and