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Choose
Ireland
The EU Gateway
#chooseireland
1
Welcome to Ireland 2
Ireland is a great place for business
and a great place to live.
Whether you are a dynamic start-up seeking guaranteed access to a
European market of 450 million people or an established business looking
to meet high performance objectives, Ireland delivers.
However, don’t just take our word for it – the list of successful companies
that have chosen Ireland proves that smart decision makers value our pro-
business policies, exceptional people and reputation as a highly attractive
place to work and live. We’re also famous for our warm welcome and ‘can
do’ attitude, so please get in touch and we’ll make sure you get the most
out of your decision to choose Ireland.
Seamus Hand
Managing Partner, KPMG in Ireland
1
2
Ireland is the location of choice
for successful businesses.
A winning combination of talented people, attractive business taxes,
commitment to the EU and an exceptional track record sets Ireland apart.
We’re home to entrepreneurs, innovators and business leaders in every
sector. They choose Ireland for many different reasons but they each have
one thing in common – a desire to succeed in a business friendly European
gateway that’s great for business and great for living. We look forward to
working with you and telling you about how - if you choose Ireland - our
KPMG teams can help your business succeed.
Anna Scally
Partner, International Tax, Head of Technology and Media & Fintech Lead
KPMG in Ireland
3
Choose Ireland delivers
Ireland
The EU Gateway
Dublin ranked 1st overall
for Large Cities
Guaranteed access to an A proven pro-business
Global Cities of the Future 2018/19 EU market of 500 million people environment
Ranked 5th in Innovation in
Knowledge and Technology
outputs
2020 Global Innovation Index
No. 1 destination in Western A transparent, consistent A highly competitive
Europe for jobs created from and certain tax environment Corporation Tax rate of 12.5%
foreign direct investment
IBM Global Location Trends Report 2019
An English speaking, committed A stable political
member of the EU and Eurozone environment and legal system
A thriving R&D environment and a A track record of delivering
strong national research ecosystem for international investors
4
The choice of winners
Ireland is the location of choice for:
• 8 of the top 10 global software
companies
• 15 of the top 15 US technology
companies
• 10 of the top 10 global
pharmaceutical corporations
• 9 of the top 10 global medical
technology companies
• 20 of the 25 leading financial
services firms globally
• 9 of the top 10 global aviation lessors
• Ireland is the 2nd largest exporter of
software in the world
5
A highly attractive corporate tax regime
Tax Certainty Knowledge Development Box
Ireland has consistent, transparent, long term tax policies. An effective rate of 6.25% may apply if undertaking R&D
in Ireland and developing patents or similar assets or
12.5% Corporation Tax Rate copyrighted software.
The lowest rate in Western Europe – applicable on trading
income of Irish resident companies and Irish branches of IP Allowances
foreign companies. Tax depreciation allowances are available on the
acquisition of a wide range of intangible assets including
Excellent Tax Treaty Network patents, software and registered designs.
74 tax treaties including US, UK, Australia, China, Canada,
Japan and Russia. Facilitates reduction in foreign taxes Start-up Relief
and withholding taxes on cross border payments. There is a 3 year exemption for new businesses where
profits are less than €320,000, with marginal relief where
R&D Tax Credit profits are below €480,000.
25% tax credit available on qualifying R&D spend -
includes staff salaries and related costs and other direct 25% Tax Rate
R&D costs. The credit is additional to the 12.5% deduction Applies to passive and non-trading income.
available for R&D spend. The credit reduces corporation
tax or is refundable over 3 years where the company is
loss making. For small and micro companies the credit is
to be increased to 30%.
The benefit can be taken ‘above the line’ i.e. before tax.
Further credits may be available on buildings used for
R&D.
6
Choose
Ireland
The EU Gateway
Tax - Corporation tax
rate of 12.5% and a
tax treaty network
with 74 countries
7Choose Ireland The EU Gateway 8
Supporting a winning
environment for innovation
R&D
Grant Aid
Allowances
for acquiring
IP
12.5%
Tax Rate
R&D
Tax Credit
Knowledge
Development
Box
9Living & working in Ireland
• Ireland is a fully committed member of the European Employment Permits:
Union - N on-EEA nationals (with a number of exceptions),
• According to the Economist Intelligence Unit’s ‘where- must have employment permits in order to take
to-be-born’ index, Ireland ranks 10th, scoring ahead of up employment in Ireland. There are a number
the US, Germany, France and the United Kingdom of different permits depending on personal
• Expats are also attracted by a beautiful unspoilt circumstances and these include:
environment, vibrant social and cultural scene and - Critical skills permit
ease of access to other countries - Inter-company transfer
• Ireland is one of very few countries with the ability to - General employment permit
pre-clear US customs and immigration at the point of
- Contract service provider
departure to the US
Investor Programme:
Visa & Permits - This is available to non-EEA nationals and their
• For non EEA nationals, and depending on personal families who commit to an approved investment
circumstances, entry visas and employment permits in Ireland. The programme is designed to facilitate
may be required participants in establishing a permanent relationship
with Ireland.
Start-Up Entrepreneur Programme:
- This enables non-EEA nationals with an innovative
business idea to secure residency in Ireland for the
purposes of developing their business
- Initial funding of €75,000 is required and €75,000 per
additional principal involved in the business
10Choose
Ireland
The EU Gateway
Ireland was
included in National
Geographic’s
Traveller’s Cool
List 2020
11Choose Our skilled workforce
Ireland
The EU Gateway
Ireland has the youngest The Irish workforce is highly skilled and adaptable. Over 25%
population in Europe of students are currently enrolled in science and engineering
with 33.3% under 25 courses, and another 25% are currently enrolled in social
sciences, including business and law.
years of age
IDA Ireland
Attainment in higher education is high among 25-34 year olds
in Ireland at 56%, which is 15% above the EU average.
Furthermore, Ireland is part of the EU open labour market thus
ensuring that your Irish based business can benefit from a
Ireland ranks in the Top 10 wide pool of European talent.
globally for quality of the
education system. Ireland also ranks 5th in the IMD Competitiveness Yearbook
2020 for business efficiency.
IMD World Competitiveness
Yearbook 2019 Ireland is also increasingly multilingual, with a wide range
of skilled people able to converse fluently in languages, in
addition to English.
Each year Ireland attracts a significant influx of foreign workers
eager to work in a dynamic and enjoyable environment with a
pro-European and diverse outlook. As a result, Ireland now has
the 4th highest international workforce in the EU.
1213
Personal taxes
Employee income tax and social security is accounted for Companies are required to operate a payroll withholding
through the payroll withholding tax system. This is known tax system (PAYE) in respect of cash payments and
as the PAYE system. benefits in kind, e.g. medical insurance and company
cars provided to employees. Certain equity based
The Irish tax year is aligned with the calendar year. The compensation is also processed through the PAYE
rates of personal tax and social security for an employee system.
in Ireland for 2020 are set out below:
A typical compensation package might include: salary,
Tax/Levies 2020 Rate bonus, stock-based-compensation (Stock options, RSU’s,
ESOP), if appropriate and other benefits.
Income Tax 20% up to €35,300*
40% thereafter
Reliefs and Incentives
Social Security Employee: 4% on total earnings There are a number of reliefs and incentives which can
Employer: 1
1.05% on total earnings reduce the personal income tax burden. These include:
Entrepreneurs Relief
Universal €0 – €12,012: 0.5%
Social Charge €12,013 - €20,484: 2% First €1m of capital gains can avail of a reduced 10% rate
(USC)** €20,485 - €70,044: 4.50% of CGT. This requires the entrepreneur to own at least 5%
€70,045 upwards: 8%*** of the equity of the company and have been involved on a
full time basis for 3 years.
Capital Gains 33% Employment and Investment Incentive (EII)
Tax (CGT) Entrepreneur’s Relief: 10% on gains
up to €1 million Individuals can secure personal income tax relief on
(after an annual exemption of €1,270) investments up to €500,000 per annum in qualifying
companies. Where investors are prepared to invest in
EII for 10 years or more, individuals can secure personal
Gift/ 33%
income tax relief on investments of up to €500,000 per
Inheritance Tax (subject to certain exempt thresholds)
annum in qualifying companies. Tax relief equal to 40% of
the investment is available.
* The 20% tax band is increased depending on marital status.
** Individuals with income lower than €13,000 are exempt from USC.
*** 11% > €100,000 for self employed.
Various tax credits and reliefs are also available depending on personal
circumstances.
14Choose
Ireland
The EU Gateway
Special Assignee Relief Programme (SARP)
Tax relief may be available to assignees transferred to
Ireland. SARP operates by reducing taxable employment
income over a threshold of €75,000 by 30%, up to
€1,000,000.
Where employees are required to perform duties outside of
Ireland, the relief will still apply.
The SARP relief is available for a maximum of 5 consecutive
tax years.
Employees who qualify for the regime can also recover the
cost of one return trip for their family to their home country
from their employer tax-free and can also have school fees
(of up to €5,000 for each child) paid by the employer tax-free.
15Choose Personal taxes continued
Ireland
The EU Gateway
Foreign Earnings Deduction
A Foreign Earnings Deduction may be available for employees who are
required to travel to work in emerging markets, i.e. Brazil, Russia, India,
China and South Africa, along with a growing number of other African,
Middle Eastern and Asian countries.
The relief provides a tax refund for the relevant employee where they
spend 30 full days working in the relevant countries in a continuous
12 month period and meet certain other conditions.
The maximum annual deduction for a relevant employee from taxable
income is €35,000.
Key Employee Engagement Program (‘KEEP’)
Ireland introduced a new share option scheme in 2017 to support start-
ups and SME’s in attracting and retaining key talent in certain sectors.
Each individual who qualifies for the scheme can be granted options
with a value of up to €300,000 over their lifetime. The market value of
share options granted under the scheme in any one year can be equal
to the employee’s emoluments in that year (certain other limitations
may apply).
Under the incentive, qualifying options will be taxed at the CGT rate,
currently 33%, rather than being subject to income tax.
16Remittance Basis • Employee contributions to Revenue approved
Non-Irish domiciled individuals who are resident in Ireland occupational pension schemes are deductible for
are taxable in Ireland on Irish source income. Foreign income tax purposes, subject to certain income and
income is only taxable to the extent it is remitted to age related limits. There is no deduction for PRSI and
Ireland. the Universal Social Charge;
• It is possible to obtain Revenue approval in respect of
Tax efficient income and benefits certain share schemes, e.g. Approved Profit Sharing
There are a number of other tax relieving provisions Schemes and SAYE Share Option Schemes which can
available to employees coming to work in Ireland,including result in tax savings for employees.
the following:
• R
elocation expenses such as shipping, storage costs
and costs associated with the purchase of a new
home (e.g. stamp duty, solicitors fees etc.) can be
reimbursed tax free;
• Accommodation and subsistence costs for the first 12
months of an assignment that is expected to last less
than 24 months can be paid or reimbursed tax free;
• Employer contributions to Revenue approved
occupational pension schemes. This exemption
can be extended to foreign employer pension schemes
in certain circumstances;
17Setting up your business
Company Set Up For entrepreneurs looking to come to Ireland to start their
Before you start doing business in Ireland, you need business, assistance is provided by Enterprise Ireland
to decide if you are going to operate through a branch (www.entreprise-ireland.com). Supports are available
or company. Most fast growing businesses choose to through the Competitive Start Fund (CSF) and High
operate through a company. Potential Start-up (HPSU) funding, mentor programmes
and workshops. In addition, Enterprise Ireland has a €10m
Irish companies are registered with the Companies fund to attract entrepreneurs to relocate to Ireland and
Registration Office (CRO), and can be formed having establish ambitious start-ups focused on international
public or private status, and with limited or unlimited markets.
liability. A company must have at least one shareholder,
which may be an individual or a corporate entity, along Financing
with a minimum of two directors in most cases, or one The Halo Business Angel Network (HBAN –
director and secretary in certain cases. At least one of the www.hban.org) and the Irish Venture Capital Association
directors must be resident in the EEA, except where there (IVCA – www.ivca.ie) are important representative bodies
is a bond in place to the value of €25,000. for angel investors and VCs in Ireland.
The incorporation of a company can be completed in a
number of ways, with the most efficient being online,
using a specific application process. Under this online
scheme, where standard constitutional documents
are used, the CRO guarantees to issue a Certificate of
Incorporation within 5 working days.
State Support
IDA Ireland provides advice, assistance, grant aid and
incentives to international companies coming to Ireland.
A wide range of supports are available from capital,
employment and R&D grants, to support recruiting talent
and finding office space. For international companies
coming to Ireland, IDA Ireland will be the principal body
responsible for providing assistance.
Further information is available on www.idaireland.com
18Choose
Ireland
The EU Gateway
60% of the Top 10
“World’s most
innovative companies”
choose Ireland
Forbes
19Choose Ireland The EU Gateway 20
How KPMG can help
We understand the pressures faced by businesses of
every type and size when locating to a new jurisdiction.
We are the adviser of choice for a wide range of start-ups
and established business who choose Ireland as their EU
Gateway. Our approach is based on simplicity and total
commitment and includes support and advice on:
• Buying and selling a • Intellectual Property
business planning
• Company set-up and • Expat tax matters
tax registration • Immigration
• Fundraising • R&D tax credits
• Regulatory matters • Transfer pricing
• Processes and controls • Both routine and more
• Cyber security complex tax and legal
• Data and Analytics matters
• Corporate and • VAT and customs duty
operating structures • Digital taxes
• Maximising group tax • Accounting advice and
benefits and minimising assistance
group tax costs • Statutory & US GAAP
• Shareholder and Audit
employee tax matters • Grant applications
What’s more, we can draw on the experience of
our colleagues globally.
For further information, please contact one of
our team or visit www.kpmg.ie
21kpmg.ie 2020 KPMG, an Irish partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. The KPMG name and logo are registered trademarks of KPMG International Limited (“KPMG International”), a private English company limited by guarantee. If you’ve received this communication directly from KPMG, it is because we hold your name and company details for the purpose of keeping you informed on a range of business issues and the services we provide. If you would like us to delete this information from our records and would prefer not to receive any further updates from us please contact unsubscribe@kpmg.ie. Produced by: KPMG’s Creative Services. Publication Date: December 2020. (6752)
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