Until recently, Ireland would not have been considered a favourable location for a holding company. This was because relatively high rates of tax were imposed on dividend income and capital gains, and because credit relief for foreign taxes suffered was quite limited. Since the enactment of its new corporate tax regime, a reduction in the rate of capital gains tax and amendments to the rules concerning credit relief for foreign taxes, however, the opportunities for using Ireland as a holding company location merits serious reconsideration by corporate treasurers when planning their international group structures.
May 31 1999