Ireland as a Holding Company Location

The Finance Act 2004, has strengthened the attractiveness of Ireland to locate a Holding company, particularly having regard to the following criteria:-

Ability to dividend income from a subsidiary to Holding company free of withholding tax;
Ability to declare dividend from Holding company without incurring any withholding tax;
No additional tax on dividend income in the Holding company jurisdiction for dividends received;
No Capital Gains Tax on disposal of shareholdings in subsidiary*
Tax deduction for borrowings to acquire shareholdings;
Absence of transfer pricing in capitalisation and CFC Rules.
A key factor is the low rate of Corporation Tax (12.5% of trading income).

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