International tax for groups that cross borders.
For Irish and international businesses with operations in Ireland, on structures and transactions that cross borders.
When a business or a family operates in more than one country, the tax result depends on where each entity is resident, how the treaties between those countries apply and how the group is financed.
We advise Irish groups expanding abroad and international groups investing in Ireland, working with their advisors in other countries where needed.
What we advise on
- Tax residency
- Interpretation and application of double tax treaties
- International holding company structures
- Foreign direct investment into Ireland
- Outbound structuring
- Tax-efficient IP structuring
- Transfer pricing, CFC rules and thin capitalisation
- Financing structures and profit repatriation
- Secondments and non-dom planning for individuals
Who this is for
- International groups setting up or investing in Ireland
- Irish businesses expanding abroad
- Individuals with cross-border careers or assets
What is a double tax treaty?
It is an agreement between two countries that decides which may tax certain income and how double taxation is relieved. Applying a treaty correctly depends on the facts and on the exact wording.
What should a foreign group consider before investing in Ireland?
Typically the choice of vehicle, how the investment is financed, how profits will be returned, and whether the group’s transfer pricing and substance support the structure.
What are transfer pricing and CFC rules?
Transfer pricing requires related-party transactions to be priced as if they were between independent parties. Controlled foreign company (CFC) rules can bring certain foreign profits into charge. Both need to be considered in group structures.
Do you work with advisors in other countries?
Yes. Cross-border structures need local input, and we coordinate with your advisors abroad, including through our international network.
This page is general information and is not advice. Speak to an advisor about your circumstances before acting.
