Ireland's economy is driven by high-technology industries and the services sector, while it has also successfully positioned itself as an investment location. The 2019 Index of Economic Freedom ranks Ireland sixth in the world and second in the European Union, while it was ranked 11th in the Forbes 2019 Best Countries for Business List. Ireland also has one of the youngest populations among EU countries with more than one-third of its population under 25 years old, providing Ireland with a significant labour force compared to neighbouring countries.
Ireland has pro-business policies and a stable tax regime, including tax treaties with more than 70 countries and territories. Ireland is ranked first in the EU and fourth in the world for the ease with which a business can pay its taxes. Other benefits include no exchange controls, and a wide range of business grants and support. Ireland has also established technology parks in several major cities to host advanced manufacturing projects and boost innovation.
On the back of Ireland's proactive stance towards fostering innovation, a number of leading Chinese companies have set up operations in the country. China is also Ireland's eighth largest export partner and its second largest outside of Europe.
What solutions are available in Ireland?
|Treasury Centres||A centralised treasury is one way to reduce the tax burden, centralise risk management, improve liquidity and enhance yield on cash.|
|Interest Optimisation||Maximise your interest yield from for your balances held with the bank.|
|Notional Pooling||Cash balances in different accounts are notionally offset to derive the net balance, which is then used to calculate interest.|
|Sweeping/ Zero Balance Account (ZBA)||ZBA are checking accounts with zero balances where funds are physically swept to eliminate excess balances and maintain greater control over disbursements.|
|Intercompany loans||Similar to bank loans, intercompany loans refer to lending between entities within the same group.|
Corporate Treasury in Ireland
Ireland is one of the founding members of the European Union. Its economy is focused on high-technology industries and the services sector. Here, we highlight some of the key benefits relevant to treasury and cash management in Ireland.
Financial Market Development
- The World Economic Forum ranks Ireland 37th in the world for its financial system in The Global Competitiveness Report 2018.
- It ranks Ireland 109th in the world for the soundness of its banks, although it is ranked 11th for banks’ regulatory capital ratios.
- Ireland has good business infrastructure, a highly educated English-speaking workforce and a sound legal environment.
- There are no foreign-exchange controls in Ireland.
Sophistication of Banking Systems
- There are 24 domestic banks in Ireland and 37 branches of foreign banks, with the sector dominated by four large banks. Three of the country's banks required government assistance during the global financial crisis of 2008.
- Ireland's foreign exchange market has an average daily turnover of USD7.2 billion (Bank for International Settlements Triennial Central Bank Survey 2019).
- Ireland has a well-developed debt market with a wide-range of both government and corporate bonds available. Outstanding debt securities were valued at USD838 billion at the end of 2018.
- The banking industry is regulated by the Central Bank of Ireland. As a eurozone country it is also covered by the Single Supervisory Mechanism Regulation and European Central Bank.
- The corporate income tax (CIT) rate is 12.5%. A higher rate of 25% is charged on income from business conducted wholly outside of Ireland, and on income from land dealing, mining and petroleum extraction. An additional profit resource rent tax of 25% to 40% applies to certain petroleum activities.
- Resident companies are subject to tax on their worldwide income. Non-resident companies are taxed on trading profits of an Irish branch or agency and certain Irish-sourced income. There is no branch profits remittance tax on the repatriation of profits to the head office by the branch of a foreign company.
- The standard rate for Value Added Tax (VAT) is 23% with certain goods and services qualifying for a reduced rate of 0%, 4.8%, 9% or 13.5%, while others are zero-rated or VAT exempt.
- Capital gains is taxed at 33%, with rates of 25% or 40% charged in certain circumstances. Some exemptions are available.
- Interest income is taxable at 25%. Interest expenses can be deducted if the borrowing is used for trade or certain non-trading assets.
- Stamp duty is charged at 6% on the transfer of non-residential property, including commercial/industrial land or buildings, as well as on business assets such as goodwill, debtors and contracts. A rate of 1% applies for the transfer of shares.
- Ireland offers favourable tax treatment for cash-pooling activities. Under a typical cash-pooling arrangement, interest payments by the Irish cash-pool leader typically constitute ‘short’ interest for tax purposes. Tax deductions for interest payable to a group company resident outside of Ireland are available.
- For entities known as 'Section 110' companies, namely Irish-resident special-purpose companies that hold and/or manage qualifying assets and meet a number of conditions, a corporation tax rate close to zero is available.
- For resident companies, there is no withholding tax (WHT) on dividends whilst WHT of 20% is charged on interest. Non-resident companies where there are no tax treaties in place, are charged WHT of 20% on both interest and dividends. Where a tax treaty is in place and the non-resident can provide the Certificate of Residence, rates range from 0% to 15% on both dividends and interest. WHT exemptions are available.
- Ireland has tax treaties with more than 70 countries and territories.
- Ireland is a signatory to the Organisation for Economic Co-operation and Development's Multilateral Competent Authority Agreement, through which information is exchanged between tax administrations, to provide a single, global picture on some key indicators of economic activity within multinational enterprises.
Benefits for Regional Treasury Centres
- Ireland is a popular location for cash pooling and treasury activities due to its low corporate tax rate.
- It offers favourable tax treatment for cash-pooling activities.
- Corporate treasury activities may be structured as stand-alone or agency operations.
- Ireland is a popular location for shared-service centres due to its highly skilled workforce and strong government support.
- Ireland is positioning itself as an alternative European financial centre for when the UK leaves the European Union.
- Most forms of cash concentration and notional pooling are available in Ireland on a domestic and cross-border basis.
- Ireland is a member of the pan-European TARGET2 real-time gross settlement system.
- Ireland has an extensive tax treaty network and offers foreign tax credit relief on foreign income not covered by this network.
- Ireland is a eurozone country with trading hours that overlap with Asia, Europe and North America.
- There are 25 domestic and 32 branches of foreign banks operating in Ireland, with the sector dominated by five main banks. After a wave of consolidations, the number of credit unions in the country fell from 292 to 262.
- Ireland was one of the hardest-hit European countries in the 2007-2008 global financial crisis. Three of the country's banks required government assistance, and the government now has majority-stakes in two of the country’s main banking groups: Allied Irish Bank (AIB) at 71% and permanent tsb at 74.9%. They also hold a minority stake of 13.95% in one of Ireland’s largest banks, Bank of Ireland.
- Ulster Bank Ireland, which operates as part of Royal Bank of Scotland due to various bank acquisitions, and KBC Bank Ireland round out the banking sector’s top five.
- There is speculation that some major international banks are considering relocating part of their operations to Ireland after the UK has left the European Union.
- Residents may hold foreign- and domestic-currency accounts both domestically and overseas. Domestic-currency accounts are fully convertible into foreign currency.
- Non-residents may hold foreign- and domestic-currency accounts both domestically and overseas. Domestic-currency accounts are fully convertible into foreign currency.
- Interest is not available on all current accounts.
Legal and Regulatory
- The Central Bank of Ireland (central bank) is an autonomous institution and a member of the European System of Central Banks (ESCB).
- The European Central Bank (ECB) supervises banks within the eurozone that are regarded as 'significant' through the Single Supervisory Mechanism (SSM), while other 'less significant' eurozone banks are supervised by the respective national central bank, such as The Central Bank of Ireland.
- A company is resident if it is incorporated in Ireland or is effectively managed or controlled in Ireland.
- Ireland has anti-money laundering and counterterrorism financing legislation in place, and follows EU anti-money laundering directives.
- There are no foreign-exchange controls in place.
- Ireland has set up a financial intelligence unit, An Garda Siochana/Bureau of Fraud Investigation (GBFI), which is a member of the Egmont Group.
On 13 January 2018, the revised Payment Services Directive (PSD2) became law across all EU Member States. A revision of the initial PSD adopted in 2007, PSD2 updates and enhances the legal framework for payment systems across the European Economic Area (EEA) single market, to be supervised by the European Banking Authority. Supplemental regulatory technical standards are also being rolled out, from March 2018 to September 2019, to address issues of authentication, monitoring and API standardisation.
The main objective of PSD2 is to provide enhanced consumer security within the developing financial technology (fintech) environment for electronic payments such as mobile payments, credit transfers, online payments and direct debits.
- Prohibition of surcharges on credit/debit card payments.
- Imposition of strict security requirements including the protection of financial data.
- Increased competition between European payment service providers.
- Greater consumer rights such as ‘no questions asked’ refunds on direct debits in euros.
(Trans-European Automated Real-time Gross Settlement Express Transfer system)
RTGS for the eurozone
|STEP1||Pan-European net settlement system|| |
Pan-european Automated Clearing House (PE-ACH)
Single Euro Payments Area
Pan-European payment infrastructure
SEPA Instant Credit Transfers
Pan-European instant payments system
SDDSEPA Direct Debits
|Pan-European direct debit system|| |
|Pan-European real-time EUR credit transfer system|| |
|EURO1||Pan-European RTGS-equivalent net settlement system|| |
(Irish Paper Clearing Company Ltd)
|Paper-based and cheque-clearing system|| |
- Can be automated or paper-based, although the large majority of credit transfers are automated. Credit transfers are used increasingly as paper-based payments are in decline.
- High-value and urgent transfers are settled through TARGET2 in real time.
- Low-value and non-urgent SEPA transfers are settled same day through STEP2.
- The SEPA Credit Transfers (SCT) scheme is used for retail transactions and is available for urgent and high-priority payments (no maximum threshold) within the SEPA.
- The SEPA Inst scheme is used for urgent transactions up to a maximum of EUR 15,000 and is available to consumers, businesses and corporations within the SEPA and SEPA-participating countries.
Direct Debits (auto debits)
- Used for low-value, regular transactions such as utility bills.
- The SEPA Direct Debit (SDD) scheme is used for urgent and high-priority retail payments (no maximum threshold) within the SEPA. It is mandatory for all banks in the eurozone to offer SDD facilities, and banks outside of the eurozone are required to accept SDD transactions.
- SEPA SDD transactions cleared same day through STEP2.
- Payment card usage continues to grow, especially with debit cards, with an 8% y-on-y increase in Q2 2019 to EUR18.9 billion. Their popularity is largely driven by an increase in contactless payment facilities and over 195 million contactless payments, with a value of EUR2.5 billion, were made in H2 2018.
- Debit card POS and ATM transactions were 5.5 times the value of credit card spending in Q2 2019.
- The main payment card brands are Visa and MasterCard, with American Express and Diners Club credit cards also in circulation. All payment cards are SEPA- and Europay, MasterCard and Visa (EMV)-compliant.
- Clearing and settlement is handled by individual banks which operate their own arrangements.
- Credit card transactions are subject to stamp duty for Ireland residents and there is a government fee imposed on ATM withdrawals. Both charges are collected annually by the card owner’s bank on behalf of the government.
- The government launched the International Financial Services 2020 (IFS2020) Action Plan 2018, outlining initiatives to support and promote financial technology (fintech) companies. Included is the Fintech Census 2018, which sets out to provide a database for domestic and international fintech companies looking to invest in Ireland’s fintech sector.
- Dublin has been named one of Europe’s financial technology (fintech) hubs (Deloitte’s Global Fintech Hub Report 2017), with a high concentration of fintech companies based there and a conducive framework in which to set up and operate.
- The Central Bank of Ireland regulates the financial sector, including the fintech industry. There is no specific fintech regulatory framework.
- The EU launched an ‘action plan on Fintech’ in 2018 that broadly sets out its approach, to be rolled out gradually. The areas of focus are: to encourage innovative business models; to support technological development in blockchain, artificial intelligence and cloud services; and to increase cybersecurity and protect the integrity of the financial system.
- Digital payments are increasing in popularity, with online and mobile transactions growing by 12.6% year on year and contactless payments using debit cards and mobile phones growing by 59.2% in terms of volume of transactions in 2018 (Banking and Payments Federation Ireland - BPFI). The most popular digital wallets are Apple Pay, Google Pay, Samsung Pay and PayPal.
- eCommerce sales in June 2019 represented 24% and 47% of debit card and credit card transaction value respectively.
- According to Visa Digital Payments Survey 2017, 78% of Irish consumers use mobile banking and about 79% have used a digital wallet such as PayPal, a card-on-file service (linked to a consumer’s online store payment details) or a mobile payment service such as Apple Pay, Android Pay or Samsung Pay.
- Reloadable prepaid payment cards are available such as Skrill, 3Money, Swirl and Payzone.
- PostFX MasterCard® Currency Card is offered by Ireland's main postal service provider, An Post. The currency card can be used at ATMs and retail outlets globally where MasterCard payment cards are accepted.
- Wearable devices offer contactless payment options through Fitbit Pay and Garmin Pay.
- Cryptocurrency has had growing interest in Ireland and is a popular investment option. There is even an Irish cryptocurrency, Irishcoin, aimed at tourists and used for low value transactions.
- There is no regulation in place for cryptocurrency, and the EU does not recognise cryptocurrencies as legal tender. The EU’s overall view of bitcoin is that “no member state can introduce its own currency”. Cryptocurrency exchanges are legal, depending on the country, and should be under the Anti-Money Laundering Directive, according to the European Commission.
- The Central Bank of Ireland has declared that in cases of ICOs, the question of whether tokens are “transferable securities” will be decided on a case-by-case basis.
- Capital gains tax law does apply to transactions involving cryptocurrencies in the event an individual earns a profit from buying or selling.
Cash, Cheques and Money Orders
- Cash remains the main form of payment for low-value transactions and the volume of ATM cash withdrawals is almost unchanged from 2016. The value of withdrawals, however, saw a Q1 2019 y-o-y increase of 5.7%, likely due to high employment rates and increasing wages.
- Cheques are a common form of cashless payment, almost double the average usage in the EU. However, cheque usage, the volume of which dropped by 13.4% y-o-y in H2 2018, is being fast-outpaced by electronic transactions.
- Cheques are used for high-value, one-off and supplier retail and commercial payments.
- The government, state and local authorities have not accepted cheques since 2013, in an effort to phase out cheque usage. However, the continued common use of cheques by businesses and the older population has slowed the phasing out process.
- Cheques are cleared through IPCC and final settlement is done through TARGET2. There is a stamp duty of EUR0.50 levied on all cheque transactions.
- Remittances can be arranged at Post offices via Postal Money Orders and Western Union for domestic transfers, and Western Union, Eurogiro and Sterling Draft for international transfers.
1 (Main) reduced and zero-rated VAT for certain goods and services
2 (Progressive) max rate but varies according to marital status and household income
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Sources: Eurostat, IMF, World Economic Forum, PwC, Central Bank of Ireland, Bank for International Settlements, European Central Bank, OECD, DBS, The Association of Financial Professionals, Banking & Payments Federation Ireland.
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