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Irish Holding Companies

Following the introduction of a number of key taxation reliefs and exemptions in recent years, Ireland has become a very attractive place for multinational companies to locate a holding company. The main features that give Ireland a competitive advantage over other jurisdictions are as follows:

• No withholding tax on dividends by the holding company to EU or tax treaty countries.
• No Capital Gains Tax on the disposal of shareholdings in subsidiaries.
• No transfer pricing, thin capitalisation or CFC rules.
• Tax deductions for interest on borrowings to acquire shareholdings in subsidiaries.
• Favourable treatment on the receipt of dividend income.
• Extensive Tax Treaty network
• Access to EU Parent-Subsidiary Directive and other Directives.

Learn more all the Holding´s Ireland tax features at Irish Holding.

A favourable Holding Company regime allows an Irish company to act as a European/Regional holding or intermediate holding company, because of the treatment of capital gains and foreign dividends benefits. Although foreign dividend income is liable to tax in Ireland it is possible to gain relief so that no further Irish tax will arise.

Companies may use a system of:

• Foreign tax credit pooling.
• The EU Parent – Subsidiary Directive.
• Double taxation agreements.

One of the major advantages that Ireland has over other jurisdictions is the ability to combine the holding company with trading activities such as

• Shared Service Centre activities,
• Group Procurement,
• Treasury (see IFSC Advantages), and
• Research & Development.

Learn more about VAT in Ireland at Irish VAT Numbers.