Corporate Treasury & Cash Management in Ireland
Corporate Treasury & Cash Management in Ireland
About Ireland
Ireland's economy is driven by high-technology industries and the services sector, while it has successfully positioned itself as an investment location. The 2021 Index of Economic Freedom ranked Ireland fifth in the world and first in the European Union (EU).
Ireland also has one of the youngest populations among EU countries. More than one-third of its population is under 25 years old, providing it with a significant labour force compared to neighbouring countries.
Ireland has pro-business policies and a stable tax regime, including tax treaties with more than 70 countries and territories. Other benefits include no exchange controls, and a wide range of business grants and support. Ireland has also established technology parks in several major cities to host advanced manufacturing projects and boost innovation. Its main export partners are the US, Belgium, and Germany.
Corporate Treasury in Ireland
Ireland is one of the founding members of the EU. Its economy is focused on high-technology industries and the services sector. In this section, we highlight some of the key factors relevant to treasury and cash management in Ireland.
Financial Market Development
- Dublin is ranked 48th in the 2021 Global Financial Centres Index by Z/Yen Group.
- Ireland is positioning itself as an alternative European financial centre, following the United Kingdom’s (UK) exit from the EU.
- Ireland has good business infrastructure, a highly educated English-speaking workforce and a sound legal environment.
- There are no foreign-exchange controls in Ireland.
- Enterprise Ireland, the Irish Government’s trade and innovation agency is the world’s second biggest financial technology (fintech) investor by deal count. The Central Bank of Ireland also operates an Innovation Hub, enabling fintech firms to engage with it outside of formal regulatory processes.
Sophistication of Banking Systems
- There are around 25 domestic banks and more than 30 branches of foreign banks in Ireland.
- Ireland has a well-developed debt market with a wide range of both government and corporate bonds available. Outstanding debt securities were valued at USD1,018 billion at the end of December 2020.
Regulatory Bodies
- The banking industry is regulated by the Central Bank of Ireland. As a eurozone country, it is also covered by the Single Supervisory Mechanism Regulation and the European Central Bank.
Tax
- The corporate income tax (CIT) rate is 12.5%. A higher rate of 25% is charged on: interest, rents, royalties, business conducted wholly outside of Ireland, income from land dealing, mining and petroleum extraction and non-trading (passive) income, including dividends from companies that are tax resident outside of Ireland. An additional profit resource rent tax of 25% to 40% applies to certain petroleum activities.
- Resident companies are subject to tax on their worldwide income. Non-resident companies are taxed on trading profits of an Irish branch or agency and certain Irish-sourced income. There is no branch profits remittance tax on the repatriation of profits to the head office by the branch of a foreign company.
- The standard rate for Value Added Tax (VAT) is 23%, with certain goods and services qualifying for a reduced rate of 0%, 9%, or 13.5%, while others are zero-rated or VAT exempt.
- Capital gains are taxed at 33%, with rates of 25% or 40% charged in certain circumstances. Some exemptions are available.
- Interest income is taxable at 25%. Interest expenses can be deducted if the borrowing is used for trade or certain non-trading assets.
- Stamp duty is charged at 7.5% on the transfer of non-residential property, including commercial/industrial land or buildings, as well as on business assets such as goodwill, debtors and contracts. A rate of 1% applies for the transfer of shares.
- Ireland offers favourable tax treatment for cash-pooling activities. Under a typical cash-pooling arrangement, interest payments by the Irish cash-pool leader typically constitute ‘short’ interest for tax purposes. Tax deductions for interest payable to a group company resident outside of Ireland are available.
- A corporation tax rate close to zero is available for entities known as 'Section 110' companies, namely Irish-resident special-purpose companies that hold and/or manage qualifying assets and meet a number of conditions.
- For resident companies, withholding tax (WHT) is charged at 25% on dividends and 20% on interest. Non-resident companies, where there are no tax treaties in place, are charged WHT of 25% on dividends and 20% on interest. Where a tax treaty is in place and the non-resident can provide the Certificate of Residence, rates range from 0% to 15% on both dividends and interest. WHT exemptions are available.
- Ireland has tax treaties with more than 70 countries and territories.
- Ireland is a signatory to the Organisation for Economic Co-operation and Development's Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations to provide a single, global picture on some key indicators of economic activity within multinational enterprises.
Benefits for Regional Treasury Centres
- Ireland is a popular location for cash pooling and treasury activities due to its low corporate tax rate and favourable tax treatment for cash-pooling activities.
- Corporate treasury activities may be structured as stand-alone or agency operations.
- Ireland is a popular location for shared-service centres due to its highly skilled English-speaking workforce and strong government support.
- Most forms of cash concentration and notional pooling are available in Ireland on a domestic and cross-border basis.
- Ireland is a eurozone country with trading hours that overlap with Asia, Europe and North America.