Content area
Abstract
Ireland has continually enhanced its holding company tax regime so that it now has an exemption from Irish capital gains tax on the disposal of qualifying shareholdings; a unilateral foreign tax credit system together with an onshore pooling of excess foreign tax credits; significant withholding tax exemptions; no specific CFC legislation or thin capitalisation rules; and no capital duty. In addition, finance act 2008 introduced new rules on the taxation of dividend income. Before finance act 2008, Irish resident holding companies were subject to Irish corporation tax at the 25% tax rate on dividends from non-Irish subsidiaries. Dividends from Irish resident companies are exempt. It is clear that Ireland has much more to offer as a holding company location than just the 12.5% tax rate on dividend income. Although not providing a complete participation exemption, the new provisions can only add to the overall package which makes Ireland the jurisdiction of choice as a holding company location.