A three-year exemption from corporation tax demonstrates Ireland’s commitment to encouraging entrepreneurship, business start-ups and employment creation. Companies that are incorporated after 14 October 2008 and commence to trade between 1 January 2009 and 31 December 2018 are granted relief on:

Profits of the new trade, and
Chargeable gains on disposals of assets used for the new trade.

Where the total amount of annual corporation tax does not exceed €40,000, a full exemption may be available. Where the corporation tax is between €40,000 and €60,000 marginal relief is given. The quantum of relief is also linked to the employers’ PRSI (max €5,000 per employee) paid by the company in the relevant accounting period. If the PRSI exceeds the corporation tax, the excess may be carried forward and offset against future corporation tax liabilities after the three-year exemption period ends.

Thanks to Irish attractive tax, regulatory and legal regime, combined with our open and welcoming business environment, Ireland’s status is well established as a world-class location for international business.

Ireland’s main tax advantages for holding companies are:

Capital gains tax participation exemption on disposal of qualifying shareholdings;
Effective exemption for foreign dividends via 12.5% tax rate for qualifying foreign dividends and a flexible foreign tax credit system;
Double tax relief available for tax suffered on foreign branch profits and pooling provisions for unused credits;
No withholding tax on almost all dividends paid to treaty countries (or intermediate non-treaty subsidiaries) and access to double taxation agreements to minimise withholding tax on inbound royalties and interest, and additional domestic provisions to minimise withholding tax on outbound payments;
Extensive double taxation agreement network.

Other key tax advantages for companies locating in Ireland include a sustainable EU-approved tax regime, which is not under threat from anti-tax haven sanctions. In addition, Ireland has no CFC rules, thin capitalisation rules, capital duty or net wealth taxes. Funding costs may also be tax-deductible.

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.