Regulated Funds In Ireland Ucits Non Ucits

Ireland
the domicile of choice for
regulated funds

First for business. First for people.

Introduction

Move from lighter-regulated jurisdictions Going forward, there will be a greater demand from
investors and regulators for more transparent and
The global financial crisis has exposed a series of highly regulated products. With this will be a move
vulnerabilities in the global financial system that need to from the lighter-regulated jurisdictions to regulated
be addressed in order to reaffirm trust and confidence jurisdictions such as Ireland. Particularly, in the
within the investment management industry. current market, investors will take greater comfort
in investing in products that offer the same complex
According to the PwC report “Transparency versus trading strategies but operating within regulated
returns: The institutional investor view of alternative structures in jurisdictions with strong regulatory
assets”, transparency and risk management were found reputations.
to be as important as returns, to institutional investors
in their evaluation of alternative asset managers. This Since its inception as a centre for the domiciliation
report based on a global survey of 226 institutional and servicing of investment funds, Ireland has
investors and alternative investment providers was positioned itself as a location for the establishment
conducted by the Economist Intelligence Unit on of “regulated” investment funds. As investors seek
behalf of PricewaterhouseCoopers in March 2008. greater transparency and comfort from investment
The report also found when it came to listing the main products and as greater regulatory oversight of
criteria for choosing a third party provider , the quality investment funds looks imminent, Ireland has a
of the compliance and risk management process and number of well established suitable products to fit
transparency ranked number two and three. In current this growing need and the experience and expertise
environment we would expect that these criteria might to support them.
now be ranked one and two.

Why choose Ireland as a domicile for your regulated funds? 1
Overview of the Irish Regulatory Environment 3
UCITS 5
Non – UCITS 9
Other Irish products & structures 13
Redomiciling a fund to Ireland 15
Taxation of Irish Funds 17
Promoters who have chosen Ireland – Top Ten 20
How PwC Ireland can help? 21

Appendix 1 23
Appendix 2 25

Why choose Ireland as a
domicile for your regulated
funds?

Ireland – a world leader Ireland – a global hub for investment funds
Key facts
• EUR 1.43 trillion in over 10,000 funds (EUR
652 bn in domiciled funds/EUR 776bn in non-
• Largest hedge fund administration centre in the
domiciled funds) as at February 2009. (Source:
world.
(Ireland services an estimated EUR 799bn in HF assets Irish Funds Industry Association (IFIA))
as of Dec 2008, representing approximately 41% of • 353 fund promoters from over 50 countries have
global hedge fund assets, Source: Irish Funds Industry
Association (IFIA) & HFM Week) set up Irish domiciled funds which are distributed
to shareholders in over 60 countries across
• Largest number of stock exchange listed Europe, the Americas, Asia and the Paciﬁc, the
investment funds. Middle East and Africa. Including non domiciled
(1,605 investment funds (2,209 sub funds) listed as of
December 2008, Source: Irish Stock Exchange (ISE)) assets, over 780 fund promoters use Ireland as
a servicing centre for investment funds. (Source:
• A leading European domicile for exchange Lipper Ireland Fund Encyclopedia 2008)
traded funds.
(Irish ETFs were valued at EUR 31.5bn as of October • Memoranda of Understanding: Ireland has
2008, Source BGI Global Investors) entered into bilateral MoUs with China; Dubai;
• Fastest growing European and UCITS fund Hong Kong; Isle of Man; Jersey; South Africa;
administration centre over the past ﬁve years. Switzerland and USA. A new MoU with Taiwan
(Irish domiciled net assets grew by 49% between 2004- is under negotiation. Within the EU, Ireland
2008; the European average for the same period was cooperates with all relevant authorities on basis of
15%, Source: Central Bank of Ireland & EFAMA)
the provisions of the European directives.
• A leading European domicile for money market • Ireland is a mature funds market with 20 years of
funds. experience in dealing with a broad range of fund
(EUR 330bn in Irish domiciled money market funds as of
Feb 2009, Source: Central Bank of Ireland) structures
• A recognised EU and OECD, open and tax • Increasing numbers of asset managers have
transparent jurisdiction with the lowest headline located in Ireland in recent years, e.g. Pioneer
corporate tax rate in the OECD. Investments, Perpetual, Fideuram Bank in
addition to indigenous asset managers such as
Abbey Capital, BIAM, AIBIM and ILIM.
• Ireland also has a very large, well established
offshore life industry.

Ireland - the domicile of choice for regulated funds
1 PricewaterhouseCoopers

Reasons for choosing Ireland • Constructive regulatory environment – robust
and efficient regulatory environment with a wide
• Innovation
variety of investment fund vehicles available
– Market driven regulated product solutions to suit individual investor needs. The Financial
– First regulated jurisdiction to commit to Regulator regulates on a ‘principled’ approach
alternative investment funds rather than on a rigid rules based system.
– At the forefront of implementing UCITS product • Ireland is a member of the EU, Euro Zone, OECD
changes and Financial Action Task Force and is continually
ranked highly in international surveys of places to
– Speed to market for sophisticated products – carry out business. Ireland is not included on any
24 hour approval international list of tax havens (e.g. OECD/G20).
– Flexible stock exchange listing options • Ireland is a modern, international, open economy
– Development of asset/pension pooling where business can be conducted with Asia in
solutions - Common Contractual Fund (CCF) the morning, the Americas in the afternoon and
Europe throughout the day.
– Newly created Shariah funds specialist unit in
the Financial Regulator • Favourable political environment - Ireland has a
pragmatic, business friendly government which
– Client focus, flexibility and ‘can do’ attitude
is committed to maintaining the competitiveness
• 12,000 skilled employees with availability of of the Irish funds industry, e.g. the publication
industry-wide training (over 9,500 employed of ‘Building on Success’, the Irish Government’s
directly by fund administrators and over 2,500 strategic plan for the development of the
employed in associated services, e.g. legal, tax, international financial services sector in Ireland.
audit, listing etc.) The Department of An Taoiseach’s IFSC
Competitiveness Group reviews and reacts to
competitiveness issues on an ongoing basis.

PricewaterhouseCoopers 2

Overview of the Irish Regulatory
Environment

The Financial Regulator is the competent authority Irish funds are most commonly established as either
for the authorisation of regulated funds in Ireland. investment companies or unit trusts.
Their duties include:
The main service providers to an Irish fund are its
• Approval of the fund promoter, investment administrator, custodian and investment manager.
manager and management company. The investment manager can be based outside of
Ireland but it is a requirement from the Financial
• Approval for the marketing of non-Irish investment
Regulator that the administrator and the custodian
funds into Ireland.
must be based in Ireland.
• Specification and approval of the fund
administrator and custodian. The Irish custodian model as required by the
Financial Regulator provides significant comfort to
• Specification and approval of the prime broker in
investors as they specifically require the custodian
the case of hedge funds.
to act in the interests of the unit holders in the
• Authorisation and ongoing supervision of Irish funds. The custodian will be directly liable to the
funds. unit holders for any unjustifiable failure to perform
its obligations or improper performance of them.
The regulatory authority in Ireland has continuously
Such duties will also extend to the custodian’s
adopted an “open door” policy in their willingness
appointment of any sub-custodians, which is of
to meet with project promoters and discuss issues
particular importance to investors where assets
directly with them. The Irish Financial Services
are likely to be held in various jurisdictions outside
Regulatory Authority (“the Financial Regulator”) is
Ireland.
seen to be innovative and proactive to the needs
of the Irish Funds Industry whilst maintaining a
There are two main fund regimes in Ireland; UCITS
reputation as a first-rate regulatory authority. One
and Non-UCITS. There are a number of factors to
such example of this innovative behaviour can be
take into consideration when deciding whether to
seen with the enhancements to the Irish Qualifying
structure an investment fund under either the UCITS
Investor Fund (QIF), where the overall time for the
or the Non-UCITS regime such as; location of target
authorisation of a QIF was reduced to 24 hours,
investors, investment policy of the fund etc.
on a filing basis only. A fast track approval process
for fund promoters has also been introduced by
The Non-UCITS regime is attractive to fund
the Financial Regulator. The Financial Regulator
managers who wish to target sophisticated investors
regulates on a ‘principles’ based approach rather
namely institutional and high net worth individuals.
than a rules based framework.
Additionally, certain funds which employ more
complex investment strategies posing greater risk
An Irish fund can be established as one of the
in return for potentially greater reward may not
following legal structures:

• Investment Company
• Unit Trust
• Common Contractual Fund
• Investment Limited Partnership


be permissible under the UCITS regime but can
be set up as non-UCITS funds. The most popular
fund structure under the non-UCITS regime is the
Qualifying Investor Fund (QIF). The QIF is seen as
a flexible fund structure and has no investment
restrictions.

On the other hand, the UCITS product is suited to
managers who would like to distribute their funds
to shareholders on a worldwide basis. The aim
of the EU’s UCITS Directive was to create a pan-
European funds market as part of the EU’s financial
services action plan, the objective of which, to
allow for open-ended funds investing in transferable
securities to be subject to the same regulation in
every Member State. It was hoped that once such
legislative uniformity was established throughout
Europe, funds authorised in one Member State
could be sold to the public in each Member State
without the requirement for further authorisation,
thereby furthering the EU’s goal of a single market
for financial services in Europe. This is commonly
referred to as a “European Passport” and is
available only to funds under the UCITS regime.
Once a UCITS fund is approved in one EU country,
application may be made to have the fund registered
for marketing to the public in any other EU country.

Furthermore, the success of the UCITS brand has
now transcended beyond the borders of the EU
and the UCITS regime is now recognised globally
as a well regulated investment product. 353 fund
promoters from over 50 countries have set up Irish
domiciled funds which are distributed to over 60
countries across Europe, Asia, the Americas, the
Middle East and Africa.


UCITS

A UCITS fund which must be open ended can avail of a “single passport” throughout the EU for the sale of its
units/shares. This means that UCITS funds established in one member state of the EU can be sold to the public
in all of the EU’s member states once the appropriate notifications have been made. They are the ideal vehicle
for promoters who wish to distribute their funds throughout the EU without having to obtain authorisation from
each Member State. The success of the UCITS structure has extended beyond the borders of the EU and the
UCITS brand is now recognised globally as a well regulated investment product. UCITS funds are distributed
heavily in Asia, the Middle East and South America as well as in Europe. There are now over 30,000 UCITS
Funds in existence with assets, according to EFAMA’s Quarter 4 Statistical Release, in excess of €4.5trillion as
at 31 December 2008.

UCITS Profile
Open/Closed Open ended
Legal Structures • Unit Trust
• Common Contractual Fund (CCF)
Samples of Investment • Fund of UCITS Funds
Strategies under UCITS • Index Tracking Funds
• 130/30 Funds
• Exchange Traded Funds
• Capital Protected/ Guaranteed Funds
• Absolute Return Funds
• Target Return Funds
• Structured products within a UCITS wrappers
• Commodity Trading Advisor (CTA Structure)
Samples of Eligible • Transferable Securities*
investments for UCITS • Money Market Instruments
funds
• Cash Deposits
• Derivatives (swaps, options, futures and forwards –FDIs)
• OTC Derivatives
• Derivatives on commodity indices
• Derivatives on hedge fund indices
• Open ended funds/ closed ended funds in specific circumstances*
Not permissible under UCITS regime:
– Direct investment in Commodities
– Physical short selling
Investor types/minimum • Retail
subscription • No minimum subscription required


UCITS Profile
Investment Restrictions • 5/10/40 rule; A UCITS fund may invest up to 10% of its assets in any one
issuer. Where the fund invests more than 5% of its assets in any issuer
the maximum amount of such holdings in excess of 5% is limited to 40%
of the net asset value of the fund. The limit of 10% is raised to 25% in
the case of bonds issued by an EU credit institution and subject by law
to protect bond holders. If a UCITS invests more than 5% of its assets in
these bonds issued by one issuer, the total value of this investment may
not exceed 80%.
• May invest up to 35% of net assets in any one security issued by a
government or public international body.
• May invest 100% of its assets in transferable securities and money
market instruments issued by an EU member state, local authorities
or governments of Australia, Canada, Japan, New Zealand, Norway,
Switzerland, the U.S. or by certain supranational organisations.
• Risk exposure of a UCITS fund to a counterparty to an OTC derivative
may not exceed 5% of net assets. This can be raised to 10% in cases
where credit institutions are listed with EEA or other specific listed
countries.
• Not more than 20% deposit with one credit institution.
• No more than 10% in unlisted securities.
• May only borrow on a temporary basis, limit is 10% of the net asset value
of the fund.
• A UCITS fund may not invest more than 20% of its net assets in any
one collective investment scheme and the schemes in which a UCITS
fund invests must be UCITS or non-UCITS schemes with the essential
characteristics of a UCITS. Furthermore, investment in non-UCITS may
not, in aggregate, exceed 30% of net assets.
• UCITS are permitted to establish non- EU based subsidiaries subject to
the Directors of the UCITS confirming the establishment of the subsidiary
complies with the UCITS Directive. Subsidiary structures in UCITS are
subject to pre-clearance by the Financial Regulator and in addition to
meeting the requirements of the Directive, the Financial Regulator has
also imposed specific conditions relating to the operation and control of
the subsidiary by the UCITS which are outlined in appendix two.
Approval Time Regulatory Approval Time:
UCITS: 4 to 6 weeks
Overall Establishment time:
(including approval of service providers)
UCITS – 3 months
* The full eligibility criteria and investment restrictions for UCITS are contained in the Financial Regulator’s UCITS notices, in particular UCITS 9 and 10.
The Financial Regulator has clarified that the above securities must comply with the eligibility criteria for Transferable Securities, specifically per the
following: - negotiability, liquidity, valuation capability, risk profile and complying with the investment objective or investment policy of the UCITS.


Ireland is renowned as a centre of excellence for UCITS products. According to the Irish Funds Industry
Association (IFIA), 80% of Irish domiciled funds fall under the UCITS regime. Additionally, Ireland is the fastest
growing European and UCITS fund administration centre over the past five years. According to the Central Bank
of Ireland and EFAMA, Irish domiciled net assets grew by 49% between 2004-2008; the European average for
the same period was 15%. The chart below highlights the main countries of distribution for Irish UCITS funds.

Markets where Irish UCITS are registered

Source: Lipper Hindsight – February
EEA
2009
Other* Note: Research is focused on fund
Taiwan groups in Ireland where the number
Switzerland of countries which they distribute to
Singapore is greater than 10. (28 fund groups
Peru match this criteria)
Macau Other countries includes:
Hong Kong
Bahamas, Japan, Gibraltar, Isle of
Chile
Channel Islands
Man, Mauritius, Qatar, South Africa,
Bahrain United Arab Emirates & the US.
EEA: European Economic Area
0 20 40 60 80 100 - includes all EU member states,
% Fund Groups Iceland, Liechtenstein and Norway.

Distribution of Irish-domiciled UCITS Investment Funds in other EU Member States and beyond
UCITS funds established in Ireland can be sold to the public in all of the EU’s member states once the
appropriate notifications have been made. The notification procedures for each member state are defined by the
UCITS Directive. There are differences from one country to another which often relate to specific local marketing
arrangements. Irish UCITS must satisfy the local regulations relating to marketing and advertising in each
country of distribution.

To market its shares/units in another EU Member State, an Irish UCITS must inform the Financial Regulator
and the supervisory authority of the host country accordingly. It must simultaneously send to that supervisory
authority:

• An attestation by the Financial Regulator to confirm that it meets the conditions necessary to qualify as a
UCITS.
• Its management regulations/articles of incorporation.
• Its prospectus/simplified prospectus.
• Where appropriate, its latest annual report and any subsequent semi-annual report.
• Details of any arrangements made for marketing its shares/units in that other member state.


Facilities must be available in the host Member State to One of the main objectives of this proposal, is the
meet redemption requests on the part of investors, to introduction of the “full management company
make payments to share/unit holders, and to provide passport”, (“MCP”). The MCP seeks to allow a UCITS
them with all required information. fund in one domicile to be managed by a Management
Company located in another jurisdiction. Greater
Irish UCITS distributing outside of the EU must satisfy efficiencies and cost savings will be gained by
the requirements of the individual countries, which operating from one core centre. Under the new regime,
varies from country to country. These should be Fund Managers will have the option to centralise their
investigated prior to the distribution of the fund. asset management, administration, risk management
operations within one domicile.
UCITS IV - The future for UCITS
The next wave of UCITS is upon us, the UCITS IV
proposal outlines new enhancements to the current
regime. It proposes to remove inefficiencies and
address administrative barriers within the current
regime through the simplification and improvement
of the rules on notification for marketing in other
Member States. The proposal also plans to meet
the demands of investment managers and retail
investors by introducing formal procedures for fund
mergers, introducing the UCITS master-feeder
structure and replacing the Simplified Prospectus
with Key Investor Information. UCITS IV does not
seek to alter the investments strategies or the scope
of eligible investments under the current regime.
The proposed enhancements seek to deliver a
pan European product by way of improving fund
distribution and creating cost efficiencies.


Non–UCITS

The term Non-UCITS is generally used to describe all Irish authorised investment funds other that UCITS. These
types of funds cannot “passport” throughout Europe. Non-UCITS are established under Irish law as opposed
to EU law which is the case for UCITS. As a result the Irish Financial Regulator is allowed more flexibility in its
dealings with Non-UCITS funds. Non–UCITS funds have more flexibility in investment strategy and borrowings
than UCITS funds and can be used for a variety of fund structures/products.

Non-UCITS Profile
Open/Closed Open ended
Legal Structures • Unit Trust
• Common Contractual Fund (CCF)
• Investment Limited Partnerships
Fund Structures • Retail Non-UCITS
• Professional Investor Fund (PIF)
• Qualifying Investor Fund (QIF)
Samples of • Hedge Funds
Investment • Fund of Hedge Funds
Strategies under
• Master Feeder Funds
the Non-UCITS
regime • Venture Capital and Private Equity funds
• Property Funds
• Capital protected futures and options funds
• Leaveraged future and options
Investor types/ • Retail Non-UCITS
minimum (No minimum subscription)
subscription • Professional investor
(Minimum subscription - Euro125,000)
• Qualifying Investor
(Minimum subscription - Euro 250,000 + wealth criteria)
Investment • Non-UCITS are subject to the Financial Regulator’s investment restrictions as
Restrictions contained in appendix one.
• All investment and borrowing restrictions which normally apply to Non-UCITS are
automatically disapplied in the case of a QIF. As a general rule the Non-UCITS
investment restrictions do not apply to the QIF. Therefore, a QIF can short sell,
employ leverage and employ/invest in a wide variety of derivative contracts (i.e.
swaps, Contract For Differences (CFDs), futures and options) and repurchase,
reverse repurchase and stock-lending agreements.
• In the case of the PIF, general investment restrictions for Non-UCITS funds are
usually doubled by way of derogation and agreed in advance with Financial
Regulator.


Non-UCITS Proﬁle
Approval Time Regulatory Approval Time:
QIF - 24 hours
PIF - 4 weeks
Retail Non-UCITS - 4 weeks

Overall Establishment time:
(including approval of service providers)
QIF - 4-6 weeks
PIF - 6-8 weeks
Retail Non-UCITS - 6-8 weeks

The Irish ‘Super QIF’
The Qualifying Investor Fund (QIF) is one of the most successful fund structures in Ireland today. QIFs are
the vehicles which are most frequently used to structure alternative investment funds including hedge funds,
funds of hedge funds, venture capital/private equity and real estate fund because of its ﬂexibility. The QIF is
the mainstay of the Non-UCITS Irish domiciled product offering. Since the enhancements to the QIF structure
by the Irish Financial Regulator in 2007, 395 QIFs (1,125 including sub-funds) have been approved. The main
enhancement being that a QIF fund can now be authorised by the Irish Financial Regulator within 24 hours of
the submission of relevant documentation to the Financial Regulator.


24 Hour authorisation – How does it work? Who can invest in QIFs?
Since February 2007, the Financial Regulator now • High-net worth individuals or institutional
authorises a QIF on a filing-only basis. Therefore, investors.
QIFs can now be authorised by the Irish Financial
• The investor must have a high degree of
Regulator within 24 hours of the submission of relevant
knowledge and experience in the relevant
documentation to the Financial Regulator provided the
markets along with a detailed understanding of
following pre-requisites are met:
the investment risks involved.
• Service providers to the fund, including the promoter, • Investment in this type of fund is limited to:
investment manager, directors, trustee/custodian
(a) an individual with a minimum net worth
and administrator must be approved / cleared by
(excluding main household and residence
the Financial Regulator in advance of the QIFs
goods) in excess of €1,250,000 or
application for authorisation.
(b) an institution which owns/invests on a
• Confirmation must be supplied regarding compliance
discretionary basis at least the equivalent of
with the authorisation criteria.
€25 million, although not necessarily in the
An application must be filed no later than 3pm on the Qualified Investor Fund.
day before the proposed date of authorisation.
• Minimum initial subscription per investor in a QIF
is €250,000, no limits made on subscriptions
thereafter.
Are there any investment restrictions?
There are no investment restrictions for a QIF.
Are there any restrictions on borrowing or
leverage?
• Where a QIF invests more than 50% of its assets in
another scheme the QIF is regarded as a feeder type A QIF is not subject to borrowing or leverage limits
investment. but the prospectus must specify the extent to which
borrowing or leverage may be used.
• QIFs established as fund of funds may invest up to
100% in unregulated schemes subject to a maximum
of 50% in any one unregulated scheme. Are there any restrictions on the use of a prime
• The Financial Regulator does not impose risk broker in relation to the QIF?
diversification requirements. It is the responsibility In the case of a QIF, there is no limit on the extent
of the directors of the investment company to to which assets may be passed to the prime
ensure that the QIF complies with the legislative broker. The following is a summary of the Financial
requirement. Regulator’s current position, for the use of prime
• Debt securities - A QIF may not raise capital from the brokers by Irish domiciled funds:
public through the issue of debt securities. However,
the Financial Regulator does not object to the • The arrangement must incorporate a procedure to
issue of notes by authorised collective investment mark positions to market daily in order to monitor
schemes, on a private basis, to a lending institution the value of assets passed to the prime broker on
to facilitate financing arrangements. Details of an ongoing basis.
the note issue should be clearly provided in the
prospectus.


• The prime broker must agree to return the same Are subsidiaries allowed with the QIF?
or equivalent assets to the fund.
Property funds using the QIF structure may establish
• The arrangement must incorporate a legally multiple layers of special purpose vehicles (“SPVs”).
enforceable right of set-off for the fund. Certain other types of funds can also use “SPVs”
subject to pre-clearance by the Financial Regulator.
Where the prime broker holds assets of the fund
greater than allowed above, it must be appointed as
a sub-custodian by the fund’s custodian. How can the use of a SPV improve tax efficiency?
The prime broker must be regulated to provide prime Investors may invest funds in the QIF to efficiently
broker services by a regulatory authority, must have manage their assets while optimising the tax treatment.
a minimum credit rating of A1/P1 and must have The QIF can hold such assets through an Irish Special
shareholder’s funds in excess of €200 million (or its Purpose Vehicle (SPV). The investment is made by the
equivalent in another currency). QIF in the SPV through a contribution of shares and
debt. The SPV may use these funds to invest in a range
There must be clear disclosure in the fund’s of assets.
documentation of its proposed relationship with the
prime broker. In practice, the SPV will not accumulate profits in
its own right. While the SPV will be within Ireland’s
securitisation regime and will be subject to Irish
Are there any redemption restrictions? corporation tax at a rate of 25% on its taxable profits,
transactions are generally structured so that the level
While open-ended QIFs may provide for dealing on
of taxable profit remaining is zero or negligible (subject
a quarterly basis, the Financial Regulator requires
to certain conditions). This is achieved by ensuring that
that the time between submission of a redemption
the level of income of the vehicle is matched by tax
request and payment of settlement proceeds must
deductible expenditure. The tax deductible expenditure
not exceed 90 calendar days. This period can
includes funding costs and service fees as well as
however be extended to 95 calendar days in the
profit-extraction payments such as interest on profit
context of a QIF feeder or fund of funds scheme,
participating debt and/or total return swap payments.
including a QIF which provides for dealing on a more
As a tax exempt vehicle, the QIF will not suffer any Irish
frequent basis (e.g. monthly, weekly etc.) In such
tax on interest income and dividends received from the
circumstances, a prominent statement highlighting
SPV.
the fact that while the scheme deals, for example,
on a monthly basis there may be times when
As a taxable vehicle, the SPV has access to Ireland’s
redemption proceeds are paid on a quarterly basis.
treaty network resulting in lower or zero withholding
taxes on investment returns.


Other Irish products & structures

The Common Contractual Fund- the Irish pooling located. Effectively, the CCF itself is expected to be
tool ignored for treaty access purposes. This facilitates
economies of scale in the management and
Common Contractual Funds (CCFs) were first
administration of asset pools, as well as preserving
established in Ireland in 2003. It was created to
the tax treaty benefits that may be available to
enable pension funds and institutional funds to pool
institutional investors through direct investment.
their investments in a tax efficient manner. This new
category of tax-exempt collective investment vehicle is
These funds will continue to appeal to multi-
constituted as a contractual co-ownership arrangement,
national companies, which have pension schemes
rather than as a company or trust and as such, they
in a number of different countries for the benefit
are comparable to partnerships or FCPs from a legal
of employees in those countries, as was the initial
perspective. They can be established as both UCITS
purpose of the vehicle. However, the tax and
and Non-UCITS funds.
regulatory improvements ensure that the CCF has
a broader appeal to fund promoters/institutions
An Irish CCF is available for investment by all investors
who want to efficiently manage their assets while
other than natural persons. The tax transparency of the
optimising the tax treatment.
CCF makes it particularly suitable for pension pooling
and it is also an excellent vehicle for asset pooling.
Exchange Traded Funds
Pension pooling allows companies operating pension
funds in several countries to ‘pool’ assets into a single The Exchange-Traded Funds (“ETFs”) sector seems
pension pooling vehicle. The pension-pooling vehicle to have been less troubled by the recent global
then invests in assets, such as global equities, bonds financial crisis than many other sectors. Although
and cash, on behalf of the investing pension funds. assets are down as a result of falling markets, new
Pooling offers considerable economies of scale, ETF’s continue to be established. This is mainly to
particularly for smaller pension funds, and this in turn due to the fact that ETF’s have high transparency,
leads to cost savings and enhanced returns. It also low costs, high liquidity and high risk diversification.
provides greater consistency in asset management and They are also tax efficient and require no minimum
enhances control over risks. investment, other than the market price of one share.
Exchange Traded Funds can be established as both
In a nutshell, pension pooling is where the pension UCITS and Non-UCITS funds.
funds in various locations operate as normal but pool
their assets in a specially designed funds structure. Ireland as a domicile for European ETFs

Asset pooling is the same concept as pension pooling,
except that the investors are not pension funds but Ireland
rather institutions or other structures pooling their 23%
assets into a single fund vehicle.

CCFs are explicitly regarded as transparent for Irish Rest of Europe
tax purposes. The tax transparency is preserved so 77%
long as the investors are not individuals. Typically,
investors include pension funds and other institutional
investors. The expectation is that the investors in CCFs Total assets of European ETFs=Euro 100 Billion
should in many cases be able to access the double Source: Barclays Global Investors, September 2008

tax agreements between their ‘home’ country and
the countries in which the securities of the CCF are


Ireland is a recognised key centre for the domiciliation and servicing of ETF products. It also has the added
benefit of being a tax efficient location for ETFs. Aside from the usual tax exemptions applicable to investment
funds and, by way of classification and definition for tax purposes, Irish ETFs may avail of reduced withholding
tax rates with the US under the Ireland/US tax treaty.

The majority of European ETFs are launched in Ireland. The availability of qualified personnel and the time it
takes to obtain regulatory approval for new products are important factors in this location choice. Additionally,
Ireland has the experience and expertise in this area as it has been a leading European domicile for Exchange
Traded Funds over the last number of years.

Money Market Funds
Money Market Funds are a type of mutual fund that provide investors with immediate availability of their money,
while offering a return comparable with or better than some alternatives. These funds hold large quantities
of short-term securities, some of which mature daily. Their purpose is to provide investors with a safe place
to invest easily accessible cash-equivalent assets characterized as a low-risk, low-return investment. Money
Market Fund investments are considered short-term, very liquid investments with a high credit quality.

Mutual fund trade groups, the Investment Company Institute and the International Investment Funds
Association, recently released their latest quarterly ‘Worldwide Mutual Fund Assets and Flows’ survey. Ireland
ranks second in money fund assets worldwide with its huge concentration of triple-A rated US dollar, euro and
sterling ‘offshore’ MMFs domiciled in Dublin. Despite the recent market turmoil, Ireland continues to have a
substantial money market fund presence. For the full table of results, see the chart below.

Irish Money Market Funds - Growth in Net Assets Largest Money Market Mutual
Fund Markets Worldwide
350
Country Assets ($bils)
300
US 3441
250
Ireland 828
200
France 668
150
Luxembourg 477
100
50
Australia 199

0
Italy 90
Canada 68
01 02 03 04 05 06 07 08
Korea, Rep. of 54
Source: Irish Financial Regulator
Spain 52
Mexico 45
Switzerland 32
Germany 31
Japan 27
China 24
South Africa 24
World 4,446
Source: Crane Data, ICI, IIFA


Redomiciling a fund to Ireland

The requirements of the Irish Financial Regulator in relation to the scheme of amalgamation are met and
relation to redomiciling a fund to Ireland are essentially that the jurisdiction in question meets with their level
the same as establishing a new fund. The main of prudential supervision.
difference is that a scheme of amalgamation would
need to take place i.e. amalgamating an offshore The fund amalgamation will only be effective if:
fund with an Irish fund. This entails going to the
unit holders in order to get their vote in favour of an • It is approved by not less than three fourths of the
in specie transfer of the assets of the offshore fund votes cast, in person or by proxy, at the meeting;
to the Irish fund. Any proposal to amalgamate must
• The votes in favour represent more than half of
obtain regulatory approval in advance of share holder
the total number of units in issue; and
notification. Amalgamating an offshore fund with a new
Irish fund can be done in a tax efficient manner. • Provision is made to the effect that the Irish
Collective Investment Scheme (CIS) will redeem
Merging or amalgamating with an Irish fund has many holdings of all non-voting unit holders prior to the
benefits as it allows fund promoters to manage a single amalgamation.
pool of assets hence reducing the overall operating
In all cases, there must be full disclosure to unit
costs.
holders of all material facts and considerations
relevant to the proposed amalgamation by the
promoter/management company.
Requirements for amalgamating an existing offshore
fund with an Irish fund
The trustee of the Irish authorised fund must review
The minimum conditions that the Irish Financial and be satisfied with the proposed amalgamation
Regulator requires for a fund amalgamation are as and confirm to the Financial Regulator in writing that
follows: it has no objection to the proposed amalgamation
being put before unit holders for approval.
• In the case of a UCITS, the fund with which it is
intended to merge must also be a UCITS. A general meeting must be held for all unit holders
• In the case of non-UCITS, the fund with which it is to consider the proposed amalgamation. All unit
intended to merge must: holders must be notified of the outcome of the
meeting. In the event that the amalgamation is
– be located in the State, another Member State agreed upon, unit holders must be advised of the
of the European Union, a Member State of procedures and deadlines by which they must
the European Economic Area (‘EEA’) (Norway, submit their redemption requests, if they so wish.
Liechtenstein, Iceland), Guernsey, Jersey or the Isle
of Man; Where the proposed amalgamation arises
– not contain restrictions on subscriptions or from a commercial decision on the part of the
redemptions which are materially different to the promoter/manager to rationalise its own activities/
non-UCITS, including the categories of target structures, they must agree to bear the costs of the
investors; and amalgamation and arrangements for winding up of
the relevant fund.
– be authorised and supervised by the relevant
competent authority. From the date of amalgamation, the investment
Funds which market solely to qualifying, and in manager must address the portfolio in advance to
exceptional circumstances, professional investors may ensure compliance with the underlying investment
be permitted to amalgamate with funds located in other policy of the non-UCITS fund.
jurisdictions on a case-by-case basis. The Financial
Regulator must be satisfied that all the requirements in

Amalgamation methods to avoid the obligation to make a non-resident
declaration.
There are two ways to amalgamate two funds:
Post amalgamation
Option One: the offshore fund transfers its assets
to the Irish fund in exchange for units in the Irish • The new merged fund can also rely on Ireland as a
fund ‘one-stop-shop’ servicing of all types of instruments.
Ireland has a well established attractive package for
• As there is no actual exchange or disposal of regulated funds. It has a highly reputable regulatory
units by the investors given that the investors environment with a wide variety of investment fund
remain invested in the offshore fund, the investors vehicles available to suit individual investor needs.
may avoid a taxable event (this will be subject to In addition to its ﬂexible, proactive regulatory
the investors’ local tax rules). environment, the Irish funds industry has a 10,000
strong workforce of skilled experts to service this
• The issue of units in an Irish fund in return for ever expanding industry.
assets is exempt from Irish stamp duty.
• Irish investment undertakings are tax exempt
• The transfer of assets to the Irish Fund may in respect of its income and gains derived from
be subject to transfer taxes in Ireland and investments, Non Irish investors do not suffer any
other jurisdictions (subject to any reliefs of that Irish withholding tax on income distributions or
jurisdiction that may be available). It should be gains realised on redemptions of shares in the
possible to structure the transaction to eliminate fund. In the case of Irish investors, withholding tax
Irish stamp duty. on distributions may apply at 25% (currently) and
Option Two: a ‘paper for paper’ or ‘share for in respect of gains on redemptions/repurchases/
undertaking’ exchange whereby units in an offshore disposals at the rate of 28% (currently).
fund are exchanged for units in an Irish fund

• The difference with this option is that the
investors receive replacement shares in an Irish
fund in exchange for their shares in the offshore
fund. The investors would not be subject to Irish
tax in respect of income or gains on their units
in the Irish fund, unless they were Irish resident
investors.
• Transfer of assets in return for units is exempt
from Irish stamp duty and from Irish VAT.
• In the case of fund amalgamations, arrangements
are available for non Irish shareholders, who
receive replacement shares in an Irish fund.


Taxation of Irish Funds

securities of the CCF are located. Effectively, the
Ireland is recognised for not having any CCF itself is expected to be ignored for treaty
banking secrecy or blockages with regard access purposes. This facilitates economies of
to the exchange of information unlike other scale in the management and administration of
offshore jurisdictions. It is the only international asset pools, as well as preserving the tax treaty
investment funds centre that is noted as benefits that may be available to institutional
having adopted the key taxation standards investors through direct investment.
and principles of the OECD. This is mainly due • Corporate tax rate 12.5% – one of the lowest
to the fact that it has no banking secrecy and in Europe and hence very attractive for service
that it has fully implemented the EU Taxation of providers, asset managers, distributors and other
Savings Directive (EUSD), meaning that Ireland corporate entities. This highly attractive corporate
is not obliged to levy a withholding tax on the tax rate, positions Ireland well in relation to UCITS
relevant interest payments as it applies the IV pan-European management companies.
exchange of information regime. Withholding tax
is applied in EU states that have yet to adopt this • No stamp duty or capital duty charges on the
Directive. establishment of a collective investment fund.
• No ongoing ‘Net Assets’ taxes.
• Double Taxation Treaties: Ireland has fifty tax
Key Tax Benefits agreements, which provide for the elimination or
mitigation of double taxation with the following
• Irish regulated investment funds are exempt from tax countries: Australia, Austria, Belgium, Bulgaria,
on their income and gains irrespective of investors’ Canada, Chile, China, Croatia, Cyprus, the Czech
residency. Republic, Denmark, Estonia, Finland, France,
• No withholding taxes apply, under domestic Germany, Greece, Hungary, Iceland, India, Israel,
legislation, on income distributions or redemption Italy, Japan, Republic of Korea, Latvia, Lithuania,
payments made by a fund to non Irish resident Macedonia, Luxembourg, Malaysia, Malta,
investors once an appropriate non resident Mexico, the Netherlands, New Zealand, Norway,
declaration is in place. Pakistan, Poland, Portugal, Romania, Russia,
Slovak Republic, Slovenia, South Africa, Spain,
• Irish collective investment funds are not obliged to Sweden, Switzerland, Turkey, United Kingdom,
charge VAT and most of the services provided to a United States of America, Vietnam and Zambia.
fund are exempt from VAT, such as, management, Planned new tax treaties: Albania, Azerbaijan,
distribution, custody/trustee, investment Bosnia Herzegovina, Moldova, Serbia, Thailand
management, distribution and administration. and a Protocol to the existing treaty with South
• Common Contractual Fund (CCF) – tax transparent Africa
vehicle - CCFs are explicitly regarded as transparent • Irish domiciled funds have access to US tax
for Irish tax purposes. The expectation is that the treaty where fund is demonstrated to be trading
investors in CCFs should in many cases be able – considerable advantage for Exchange Traded
to access the double tax agreements between Funds.
their ‘home’ country and the countries in which the
• Based on experience, the Irish Vaiable Capital
Company (VCC) has more beneficial effective
tax reclaim rates in continental Europe (Belgium,
France, Germany and Italy) as well as in Australia,
Japan and Korea.


Tax Exemption Taxation of an Irish Resident Unitholder
Irish resident investors may invest in Irish funds. The
To qualify for tax exemption in Ireland, a collective
Irish fund is obliged to undertake tax reporting and
investment fund must take one of the following
deduct Irish tax on the happening of chargeable events
forms:
where the investor is a non exempt Irish resident
investor. Such tax returns need to be made every six
1, A unit trust authorised by the Unit Trusts Act
months by the fund.
1990
2, A designated variable capital investment A chargeable event includes any distribution payments
company to Unitholders or any encashment, redemption,
cancellation, transfer of units or appropriation or
3, An investment limited partnership
cancellation of a Unitholder by the fund for the
4, A common contractual fund (CCF) not purposes of meeting the amount of tax payable on a
constituted as a UCITS fund gain arising on a transfer.
5, A non-designated variable capital investment
company that is only available to ‘collective A disposal is deemed to arise where shares have been
investors’ – deﬁned as any investor investing held for eight years (and at each subsequent eight
money on behalf of as least 50 people and none year anniversary), to the extent that the investor is a
of these persons own more than 5% of the non exempt Irish resident/ Irish ordinary resident in
moneys invested, for example a pension fund or Ireland. Any tax paid in respect of any deemed disposal
life assurance company). is creditable against any tax payable on the ultimate
disposal of the relevant fund investment.

Taxation of a non-Irish resident Unitholder A chargeable event does not include:
No Irish tax arises on the happening of chargeable
events where the investors are neither Irish resident/ • An exchange by a Unitholder, effected by way of an
Irish ordinary resident and who have made the arms length bargain where no payment is made to
relevant declaration to that effect to the fund. the Unitholder of Units in the fund for other units in
the fund;
The tax declaration requires all non-Irish investors to • Any transactions (which might otherwise be
declare that they are not Irish residents when they a chargeable event) in relation to units held in
are applying for shares/units in a fund. Subsequent recognised clearing system as designated by order
applications for shares/units in the same fund (or of the Irish Revenue Commissioners (e.g. units in
umbrella fund) or any other Irish domiciled fund an Exchange Trade Fund are normally held through
promoted by the same fund promoter do not require clearing systems);
a declaration to be made regarding an investor’s
tax residence position (unless the investor’s non • A transfer by a Unitholder of the entitlement to a Unit
residence status has changed since the original where the transfer is between spouses and former
declaration was made). spouses, subject to certain conditions; or
• An exchange of units arising on a qualifying
amalgamation or reconstruction (within the meaning
of Section 739H of the Taxes Act) of the fund with
another investment undertaking.


Tax currently at the rate of 25% is required to be deducted by the fund
from a distribution (where payments are made annually or at more
frequent intervals) to an investor who is Irish resident/Irish ordinary
resident. Similarly, tax currently at the rate of 28% must be deducted
by the fund on any other distribution or gain arising to the investor on
a disposal, redemption or transfer of shares by an investor who is non
exempt Irish resident/Irish ordinary resident.

In general, the above tax is the full and final liability for Irish individuals.
In the case of institutional investors, the ultimate tax liability will
depend on whether or not the investment return arises in respect of
a trade. In the case of trading profits, the relevant tax rate is 12.5%,
while the relevant company would be entitled to a credit for any tax
deducted from any payment by the fund. In the case of non-trading
companies, income distributions are ultimately subject to tax at
25%, while the 28% tax deducted by the fund in respect of gains on
redemption is deemed to be the full and final liability.

Where tax has not been deducted by the fund, any tax due by Irish
investors is accounted for by the investor through the self assessment
regime.

Tax Exemption for Certain Irish Investors
There are a number of Irish resident investors that are specifically
excluded from this tax (i.e. 25% on distributions and 28% on gains
arising on chargeable events). Declarations are also required to be
made by the categories of exempt Irish Investors prior to the receipt of
distributions or gains to ensure that no Irish tax is suffered on income
distributions or gains made on redemption. Examples of exempt Irish
investors include Irish pension funds, Irish life assurance companies
and Irish charities.


Promoters who have chosen
Ireland – Top Ten

Ireland Promoters
Domiciled Market Share Ranking by Assets as at 30 June 2008
Company Name Assets in US$Million Prior Year Assets in US$Million
1. Barclays 163,877 134,052
2. Goldman Sachs 99,910 81,905
3. HSBC 56,268 37,268
4. Russell Investments 48,492 53,824
5. Vanguard Group 39,219 36,648
6. Royal Bank of Scotland 39,048 12,609
7. Insight Investment 36,315 28,556
8. State Street 29,132 19,513
9. Blackrock Financial Management 27,979 16,837
10. PIMCO 25,763 21,313
Total Dublin Domiciled Fund 1,240,859 1,100,182
Source: Fitzrovia ﬁgures @ 30/06/08


How PwC Ireland can help?

Audit Services Advisory Services
PwC also provides a full range of business
Our audit approach is tailored to suit the size and nature
advisory services for both large organisations and
of your organisation and draws upon our extensive
independent advisors entering the investment fund
industry knowledge. In addition to the independent
business. Our business advisory services team can
audit, we offer advisory services in the areas of
assist clients in making strategic assessments of
financial reporting, corporate governance, regulatory
the investment business, preparing business plans
compliance, independent controls and risk assessment.
and economic analyses as well as advising on the
structure of both the investment advisor and the
underlying fund. The team can also offer advice
Tax & Legal Services
on systems and operational needs, identifying and
Our Tax and Legal Services formulates effective selecting outside vendors and preparation of full
strategies for optimising taxes, implementing innovative documentation of policies and procedures.
tax planning and effectively maintaining compliance.

In recognition of the international tax issues to be
considered in structuring funds, our specialised tax
team works extensively with our global investment
Our market share
management teams on an ongoing basis.
Irish-combined (Irish and non-Irish domiciled) market share

Regulatory Services
PwC has a dedicated regulatory and compliance service KPMG PwC
team to assist you with all aspects of financial services 23% KPMG
regulation. The regulatory and compliance services
team provides support and advice to help you identify, PwC E&Y
manage and control any existing and future regulatory 55% E&Y
risks. Our services can be broadly categorised under Deloitte
17%
four main headings: Other
• Market entry; feasibility studies, authorisation
services, governance arrangements, compliance Deloitte
frameworks, capital adequacy arrangements and Other 4%
notification assistance 1%
• Regulatory risk and compliance management Source: Funds Encyclopaedia June 2008

• Assistance with continuing regulatory obligations
• Responding to regulatory change


Appendix 1

Non-UCITS investment restrictions 4, In the case of an equity exchange index tracking
scheme the limit of 10 per cent in point 2 may be
1, A fund may not invest more than 10 per cent of its increased to 20 per cent subject to the following
net assets in securities which are not traded in or conditions:
dealt on a market which is provided for in the trust
– The investment objective of the scheme must
deed, deed of constitution, articles of association
be to replicate a particular index. The weighting
or partnership agreement. Restrictions in respect
of securities of a specific issuer in the scheme’s
of markets may be imposed by the Financial
portfolio must closely correspond to the
Regulator on a case by case basis.
weighting of those securities in the relevant index.
2, A fund may invest no more than 10 per cent of Deviations should be temporary and related to
its net assets in securities issued by the same operational difficulties. Deviations in excess of
institution. Where a fund has as a sole objective, 0.5 per cent of the net asset value of the scheme
investment in Irish equities, it may derogate from must be rectified without delay;
this limit as follows:
– The index must be sufficiently diversified and
– An investment of up to 15 per cent of net assets represent an adequate benchmark for the market
may be made in an equity which has a weighting to which it refers;
in excess of 10 per cent in the ISEQ index;
– The index must be published and be freely
– An investment of up to 12.5 per cent of net assets available;
may be made in an equity which has a weighting
– The prospectus must clearly set out these
of between 8 per cent and 10 per cent in the
conditions.
ISEQ index.
5, A fund may not hold more than 10 per cent of any
3, No more than 10 per cent of the net assets of
class of security issued by any single issuer. This
a scheme may be kept on deposit with any
requirement does not apply to investments in other
one institution; this limit is increased to 30 per
collective investment schemes of the open-ended
cent for deposits with or securities evidencing
type.
deposits issued by or securities guaranteed by the
following: 6, A fund may, subject to authorisation by the
Financial Regulator, invest up to 100 per cent
– a credit institution authorised in the European
of its assets in transferable securities issued or
Economic Area (EEA) (European Union Member
guaranteed by any State, its constituent states,
States, Norway, Iceland, Liechtenstein);
its local authorities, or public international bodies
– a credit institution authorised within a signatory of which one or more States are members. Full
state, other than a Member State of the EEA, to disclosure must be made in the prospectus
the Basle Capital Convergence Agreement of indicating the States, local authorities and public
July 1988 (Switzerland, Canada, Japan, United international bodies in the securities of which it is
States); intended to invest more than 10 per cent of the
assets in accordance with the provision of the
– a credit institution authorised in Jersey, Guernsey,
preceding sentence.
the Isle of Man, Australia or New Zealand;
– the trustee;
– a credit institution which is an associated or
related company of the trustee, on a case-by-
case basis.


7, A fund may acquire the units of other open-ended 9, A fund is permitted to engage, to a limited extent,
collective investment schemes subject to the in leverage through the use of techniques and
following: instruments permitted for the purposes of efficient
portfolio management under the conditions
– a scheme may not invest more than 20 per cent
contained in NU 16. The net maximum potential
of net assets in such schemes;
exposure created by such techniques and
– a scheme may not invest more than 10 per cent instruments or created through borrowing, under
of net assets in unregulated schemes1; the conditions and within the limits contained in
– where a scheme invests in units of a collective NU 3, or through both of these together, shall not
investment scheme managed by the same exceed 25 per cent of the net asset value of a
management company or by an associated or scheme. The prospectus must disclose a scheme’s
related company, the manager of the scheme in intention to engage in leverage.
which the investment is being made must waive The above is by way of summary of the general
the preliminary/initial/redemption charge which it investment restrictions that apply to Non-UCITS
would normally charge; funds. For further reference see: http://www.
– where a commission is received by the manager financialregulator.ie/industry-sectors/funds/non-ucits/
of the scheme by virtue of an investment in the Pages/default.aspx
units of another collective investment scheme,
this commission must be paid into the property of
the scheme.
8, The Financial Regulator may allow derogations
from the limits laid down in this Notice to a scheme
investing in other collective investment schemes or
companies which are authorised or incorporated
in a non- EU state and where such collective
investment schemes or companies invest their
assets in the securities of issuing bodies which
have their registered offices in that state and where
under the legislation of that state such a holding
represents the most effective way in which the
scheme can invest in the securities of that state.


Appendix 2

UCITS & Non-EU subsidiaries • The prospectus must disclose; the name of the
subsidiary and that the subsidiary is wholly owned
The Financial Regulator’s recent clarification by the scheme.
now permits UCITS to establish non- EU based
• The shares in each subsidiary must be registered in
subsidiaries subject to the Directors of the UCITS
the name of the trustee.
confirming the establishment of the subsidiary
complies with the UCITS Directive and in particular, • The underlying assets must be registered in the
Article 25 (e); (shares held by an investment company name of the trustee or in the name of the scheme
or investment companies in the capital of subsidiary or its subsidiary. The trustee must be appointed as
companies are only carrying on the business of trustee to each subsidiary and must be in position
management, advice or marketing in the country to demonstrate to the Financial Regulator that it
where the subsidiary is located, in regard to the has sufficient controls in place in relation to each
repurchase of units at unit holders’ request exclusively layer of the subsidiary structure.
on its or their behalf).
• The assets of each subsidiary must be valued by
the scheme or its delegate.
Subsidiary structures in UCITS are subject to pre-
clearance by the Financial Regulator and in addition Source: Irish Financial Regulator’s website – http://
to meeting the requirements of the Directive, the www.financialregulator.ie
Financial Regulator has also imposed specific
conditions relating to the operation and control of the
subsidiary by the UCITS as follows:-

• The subsidiary must be a private limited company.
It cannot be a plc, collective investment scheme or
an issuing body in its own right.
• The subsidiary must be wholly owned by the
scheme.
• The directors of the scheme form a majority of
the board of the subsidiary and must maintain full
control over the activities of the subsidiary.
• The subsidiary must not appoint any entity directly.


PwC Investment Management
Contacts - Ireland

Olwyn Alexander Tony Weldon
Tel: +353 1 792 8719 Tel: +353 1 792 6309
Email: olwyn.m.alexander@ie.pwc.com Email: tony.weldon@ie.pwc.com

Pat Candon Advisory
Tel: +353 1 792 8538
Email: pat.candon@ie.pwc.com Andy O’Callaghan
Tel: +353 1 792 6247
Fiona De Burca Email: andy.ocallaghan@ie.pwc.com
Tel: +353 1 792 6786
Email: ﬁona.deburca@ie.pwc.com
Robin Menzies
Patricia Johnston Tel: +353 1 792 8553
Tel: +353 1 792 8814 Email: robin.menzies@ie.pwc.com
Email: patricia.x.johnston@ie.pwc.com
Tax & Legal Services
Joanne Kelly
Tel: +353 1 792 6774 Jim McDonnell
Email: joanne.p.kelly@ie.pwc.com Tel: +353 1 792 6836
Email: jim.mcdonnell@ie.pwc.com
Andrea Kelly
Tel: +353 1 792 8540 Pat Wall
Email: andrea.kelly@ie.pwc.com Tel: +353 1 792 8602
Email: pat.wall@ie.pwc.com
Vincent McMahon
Tel: +353 1 792 6192 Pat Convery
Email: vincent.macmahon@ie.pwc.com Tel: +353 1 792 8687
Email: pat.convery@ie.pwc.com
Damian Neylin
Tel: +353 1 792 6551 John O’Leary
Email: damian.neylin@ie.pwc.com Tel: +353 1 792 8659
Email: john.oleary@ie.pwc.com
Jonathan O’Connell
Tel: +353 1 792 8737 Real Estate
Email: jonathan.oconnell@ie.pwc.com
Enda Faughnan
Marie O’Connor Tel: +353 1 792 6359
Tel: +353 1 792 6308 Email: enda.faughnan@ie.pwc.com
Email: marie.o.connor@ie.pwc.com
Regulatory and Compliance Services
Ken Owens
Tel: +353 1 792 8542 Deirdre McManus
Email: ken.owens@ie.pwc.com Tel: +353 1 792 7356
Email: deirdre.mcmanus@ie.pwc.com


This publication has been prepared as a guide only. In the interests of brevity and clarity, detailed information may be omitted which may
be directly relevant to an individual’s or an organisation’s circumstances. Professional advice should always be taken before acting on any
information contained in this publication. Re-publication and dissemination (other than brief quotations with appropriate attribution) is expressly
prohibited without prior written consent.
Designed by PwC Design Studio (01810).

pwc.com/ie
© 2009 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the
network of member ﬁrms of PricewaterhouseCoopers International Limited, each of which is a
separate and independent legal entity PricewaterhouseCoopers, One Spencer Dock, North Wall
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