Ireland in international tax planning

This is the first detailed investigation of Ireland's position in international taxation, and the first to explore in depth the attractions of the Irish tax system for foreign investment and international transactios. The book has been written principally with those unfamiliar with the Irish tax system in mind; consequently, an introduction to Irish tax legislation is provided, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Ireland's domestic legislation is outlined alongside the corresponding treaty provisions in the OECD Model Convention, and the interrelation between the two is disussed. A practical discussion of Ireland's tax breaks then follows, most significant of which is manufacturing relief; the author provides a definition and examines in depth how the relief is calculated, the advantages and disadvantages of an Irish resident subsidiary, as opposed to a permanent establishment, and tax-efficient financing. Tax planning opportunities offered by Irish trusts are explored as well as various tax breaks for specific business, individuals and locations, including writers and artists, air and sea transport, forestry, bloodstock, international executives, self-employed professionals and Shannon Airport and the International Financial Services Centre. The book also covers transfer pricing and anti-avoidance legislation in an Irish context.