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Date: 2016-08-12

Should Your Company´s Tax Home Be in Ireland?

The business press was ablaze in late November, as news broke that pharmaceutical giant Pfizer planned to sell itself to the far smaller Irish pharmaceutical firm, Allergan—a deal valued at $160 billion USD.

The proposed merger is widely acknowledged to be a strategy to lower corporate taxes. Pfizer’s current year tax bill, estimated at about 25 percent, will drop to roughly half that thanks to moving its corporate tax home to Ireland.

Ireland’s 12.5 percent corporate rate, however, says Frank Keane, international trade partner of the chartered accountants and financial services firm, EisnerAmper Ireland, is just one of many ways it’s made itself a welcome home for business. While EisnerAmper Ireland’s client list is heavily focused on SMEs, its biggest client is the Irish government itself. So Keane has greater insights than most into doing business in the country.

“That 12 ½ percent is a fixed rate. It's not subject to negotiation and deals.” That means companies can better plan for the future, knowing what they will pay today is what they will pay tomorrow.

“We've also written our tax legislation to make it easy for companies to have holding companies in Ireland,” says Keane. “When they pay dividends or licenses up to the Irish company, there's no withholding tax. It allows you to handle your European affairs in an Irish company in a very efficient manner.”

Just as important, there is very little bureaucracy to slow business down. “In Ireland, you can set up a company in five or six days. You can open a bank account in about a week.”

This streamlined approach often takes businesses by surprise, says Keane. “We often get asked by companies around the world, ‘Do you need a license to have an office?’ No. ‘Do you need to sign up with the local authority?’ No. ‘Do you need to have your staff handbook signed off on by the employment rights office?’ No.”

Ireland has earned awards as the easiest place in the world to do business, thanks to all these factors, not just taxes.

And Keane doesn’t think you should consider Ireland for its rates alone. Ireland is, in fact, a signatory to OECD guidelines developed for the express purpose of discouraging businesses from opening dummy offices in far-flung locales simply to lower taxes. The guidelines say that taxes should be paid where value is added.

“The bottom line is that the company should be trading from where the decision-makers are based,” says Keane. “If you're trading and selling in Europe and you want to have French customers and Italian customers and German customers, then it makes sense for you to have people who understand the language, who understand the culture. On that basis, it makes sense for you to have a European operation. If you do, Ireland is the place to be.”

And, if Ireland is the place to be, EisnerAmper Ireland might be the right firm to help you map out your international strategy.

“We are accountants and tax advisers,” says Keane. “That's what we get paid for. The way we help is our understanding of what we call internationalization for those looking into entering international trade.” Keane says that his firm learns everything about a client’s business model and entry strategy so they can assist in helping them plan the right structure for their trade. “And if they don't know it, we help them with it.”

For some companies, it makes the most sense to keep their base where it is now, and just trade with Ireland. “Others will look to have an employee in say the UK to handle their sales. Or we could deal with a company that thinks it needs to have a rep in each country.”

And, of course, as chartered accountants, “We also discuss things like international tax and sales tax to make sure that the transactions are going to give them the most returns to the company.”


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