Aidan Byrne specialises in advising mid-market corporate client many of whom have international operations, ensuring that they are fully compliant and are structured as efficiently as possible.

TAX ISSUES The recent BEPS changes are certainly on the minds of our international clients. Ensuring that structures which were implemented over the past few years are still fit for purpose is a key concern for these clients. The Irish tax regime is very attractive for businesses that are prepared to establish here, and we have worked extensively with clients that are looking to bring their IP onshore from jurisdictions that no longer work in the post-BEPS landscape.

By and large, these clients plan to place R&D centres and commercial functions here around IP exploitation. We also continue to assist business to put robust structures in place of the ‘double Irish’, which will close on 31 December 2020.

Domestic clients have commented that whilst the compliance burden has been raised over the past number of years the level and quality of service from Revenue has decreased without any real level of accountability being visible for this drop-in service levels. Many clients have asked us to refrain from being more pro-active in following Revenue up when delays are experienced for fear of ’targeted’ by them as a result of such follow up.

Many of our clients are reviewing both their structure and their supply chain and operations to understand the potential risks and to prepare for the outcome of the Brexit negotiations. Others are taking a wait and see approach, which we do not recommend. There are simple steps that can be taken now that would mitigate against a hard Brexit result.

R&D CREDIT The current system is overly time consuming for smaller clients. Many are taking the decision to forego the relief rather than risk either getting it wrong or spending an inordinate amount of time compiling it. 

We apply a project management approach to R&D with clients. We ensure that their systems are set up correctly from the start so that the information required to complete an accurate and correct claim is compiled as each project progresses. Where necessary we bring in technical expertise to give that additional level of comfort to clients should they require it.

TAX REFORM The 52% marginal tax rate is prohibitive in terms of attracting top executives to relocate here, and is a live issue for all of our FDI clients. With Brexit on the horizon, we would expect that this matter should be high on the agenda for Budget 2018.

 

*As published in Business Plus magazine, 6th September, 2017