Case Studies:
“The IMC team is efficient, reliable and displays a very comprehensive understanding of the needs of companies seeking to do business in Ireland, from both a commercial and compliance perspective” -PricewaterhouseCoopers
General Introduction IRCO is a subsidiary of a US privately owned company, US Inc. US Inc. was established over ten years ago and the company is engaged in the manufacture and distribution of its products, which are sold to distributors, retailers and end users within the product field. US Inc. made a decision to increase its market share and establish a European business base, which it will use as a platform for European sales and hence IRCO was established to cater for all European business.
Critical factors influencing the decision to locate its European business base in Ireland were:
How Irish Managed Companies (IMC) assists IMC worked with US Inc. from the outset of establishing its Irish operations and initially handled all aspects of:
Currently, IRCO imports its products into Ireland from the U.S. All logistics, warehousing, customs and excise and onward distribution of the product is handled by the third-party warehousing facility.
There is a Management Services Agreement between IRCO and IMC, whereby IMC provides the following:
IRCO also has a marketing manager who works from a dedicated office in our building. This employee is tasked with the responsibility of establishing and developing a European strategy with regard to the market penetration and sales growth of IRCO's products throughout Europe.
Conclusion IMC provided IRCO with an operational Irish office at an annual cost of circa one-third less than a stand-alone office solution, with access to local knowledge, financial administration, accounting and company secretarial skills whilst also availing of the associated economies of scale. IRCO has also benefited from the participation of a senior Irish director on the board. The set-up of the full office infrastructure has enabled the marketing manager to focus on sales development and market growth. In summary, IMC has provided a turnkey solution which enabled IRCO to commence and continue trading in Ireland in a cost-effective and timely manner. back to top>>
Tax Migration – Changes in Tax Legislation
General Introduction Ongoing changes in global tax legislation can have an adverse impact on the economic environment in which a company operates, with the result that certain companies, after engaging in effective tax analysis and planning, have found it beneficial to migrate their tax residency to Ireland.
How Irish Managed Companies (IMC) Assists IMC has assisted a number of clients in their corporate re-organisation or tax migration to Ireland from various jurisdictions. We provide a range of support services in the period prior to the tax residency move in order to facilitate a seamless transition, as well as ongoing operational, administration and financial reporting infrastructure in Ireland. Services include post-migration corporate compliance and administration of the company’s tax affairs.
Conclusion IMC can ensure that companies migrate their tax residency to Ireland in an efficient and effective manner. back to top>>
General Introduction Foreign businesses who establish a company or branch in Ireland do so for a number of reasons. After seeking appropriate tax advice, the foreign business may have established an Irish company/branch in order to take advantage of the country’s double tax treaty network. Alternatively, the Irish entity may form part of an overall global corporate restructuring. The foreign business may thus require an outsourcing solution to administer and account for the activity of the Irish entity.
How Irish Managed Companies (IMC) Assists IMC has Management Services Agreements with various such entities and in essence, we provide the necessary financial reporting and administration infrastructure for these companies. IMC deals with all aspects from day-to-day bank movements, through to year-end financial reporting and annual return filings.
Conclusion IMC can help overcome the problems which several foreign companies encounter when establishing an entity in Ireland that has limited movements throughout the year but still needs a level of administration, financial reporting and corporate governance. back to top>>
General Introduction A US Group involved in technology solutions underwent a corporate restructuring designed to better enable the organisation to meet the growing demands for its technologies and products. Following extensive research, the Group determined that Ireland was the best location to headquarter its global business within an efficient and workable corporate structure.
In the revised structure, the new IRCO acquired the US-held intellectual property (IP) at current market value. Following the migration, IRCO licenses this technology from Ireland to third-party customers and through existing and new subsidiaries in other jurisdictions delivers the required services and technological support to their customers.
The Board of Directors of the IRCO meet on a regular basis to make strategic decisions and agree on the most commercial way to implement these policies within the global operation and ensure the business is appropriately managed. The IRCO also engages in the sale of products manufactured by external contract manufacturers by leveraging their existing IP capabilities, as well as managing the further development of its technologies and customers by employing, where necessary, the requisite resources in the US, Japan and elsewhere to implement its corporate objectives.
How Irish Managed Companies (IMC) Assists IMC facilitated the restructuring through the provision of management services in Ireland. In the initial stages, IMC provided the IRCO with the necessary infrastructure in a timely and efficient manner, ensuring that the Irish entity was legally formed by registering it with the Companies Registration Office, registering the IRCO for relevant taxes and opening the necessary Irish bank accounts.
IMC continues to provide day-to-day support and assistance in a variety of business areas:
Conclusion IMC provided the US Group with an economical solution to its proposed restructuring by establishing an Irish structure and providing a suite of tailored services in a seamless manner. The US Group was thus able to achieve its desired global operation with limited management time, shared costs and no compromise on delivery. back to top>>
Ireland: Holding Company Structure
General Introduction Foreign businesses looking at establishing a new holding company are now considering Ireland as a potential solution. Ireland’s holding company regime has several benefits, including providing a tax exemption on capital gains where an Irish holding company disposes of shares in another company (the investee company). It has a distinct advantage over other holding company jurisdictions with specific advantages in tax-efficient investment into China, Japan and Korea. Ireland also provides credit pooling for foreign dividends.
How Irish Managed Companies (IMC) Assists IMC manages a number of Irish holding companies where clients have established a holding company in Ireland and these holding companies are used to invest in a variety of jurisdictions, with China being the most common. IMC actively assists with the management and control of Irish holding companies, together with the commercial aspects pertinent to such a structure.
Conclusion Clients can obtain a tax-efficient managed vehicle that provides access to the benefits of Ireland’s holding company regime with particular benefit in jurisdictions such as China and other Asian countries. back to top>>
General Introduction IRCO is a wholly owned subsidiary of another EU entity, which is involved in leasing equipment to international clients. The IRCO leases its equipment from the parent company and subleases it to various international clients.
The IRCO established its equipment leasing business in Ireland for fiscal and regulatory reasons; specifically, Ireland’s attractive corporate tax rate and the provision of a better legal framework.
How Irish Managed Companies (IMC) Assists IMC initially provided the IRCO with a 10% tax licence duly obtained from the Department of Finance. The IRCO has now rolled out to a 12.5% company effective from January 1, 2006.
IMC also assists in
Conclusion In essence, IMC provided all the resources necessary to manage and run the IRCO’s equipment leasing business. back to top>> |
