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Introduction
        
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 the payment of 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 and access to EU Parent-Subsidiary Directive.
      
Low tax rates for both trading operations and investment activities.
      
      
These incentives together with non-tax incentives such as the economic and telecommunications infrastructure, the English speaking population and membership of the EU make Ireland one of the most attractive destinations in Europe for multinational companies.

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, GroupProcurement, Treasury and Research & Development.
      
      
        
        
Byrne & McCall, Core B, Block 71, The Plaza, Park West, Dublin 12   Tel: +353-1-6120580   Fax:+353-1- 6205625   Email: info@byrnemccall.ie
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