1. Assurance and Business Advisory Services
Investment Funds
Ireland the One Stop Shop
for Investment Funds
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.
The location of choice for the establishment of
management companies, domiciliation of funds
& excellent experienced servicing of all types of
instruments.
First for business. First for people.
2. Twelve Compelling Reasons Tax Benefits process is not the responsibility
to choose Ireland of any designated individual.
• No banking secrecy or exchange
• Irish funds distribute to over 60
1. Highly regarded and well regu- of information blockages - Ireland
countries across Europe, the
lated environment for investment is not regarded as a “Tax haven”
Americas, Asia, the Middle East
funds. and is recognised by the OECD
and Africa. 353 fund promoters
as having implemented their
from over 50 countries have set
2. Ireland is the largest hedge fund required taxation standards and
up Irish domiciled funds and
administration centre in the principles for the sharing and
over 780 fund promoters use
world. exchanging of information.
Ireland as a servicing centre for
• Irish regulated investment funds investment funds.
3. A leading cross border jurisdic- are exempt from tax of their
tion for Exchange Traded Funds • Memoranda of Understanding:
income and gains irrespective of
and Money Market Funds in Ireland has entered into bilateral
investors’ residency.
Europe. MOU’s with the following
• No withholding taxes apply for jurisdictions outside the EU:
4. Largest number of stock ex- non Irish resident investors. China, Dubai, Hong Kong, Isle
change listed investment fund of Man, Jersey, South Africa,
(1,605 investment funds (2,209 • Irish collective investment funds Switzerland and the USA. Future
sub funds) listed as of Dec 2008, are not obliged to charge VAT and MOU planned with Taiwan.
Source: Irish Stock Exchange). most of the services provided to
a fund are exempt from VAT. • Fastest growing European and
UCITS fund administration centre
5. Flexible, proactive regulatory • Lowest headline corporation tax over the past five years (Irish
environment. in the OECD - 12.5%. domiciled net assets grew by
• Common Contractual Funds 49% between 2004-2008; the
6. Speed to market: 24 hour ap-
(CCFs) – tax transparent vehicles. European average for the same
proval process available for
period was 15%, Source: Central
Qualifying Investor Funds (QIFs) • No stamp duty or capital duty Bank of Ireland & EFAMA).
and an average 4-6 weeks for all charges on the establishment of a
other fund structures. collective investment fund. • Promoter financial resources
requirement: Irish promoters must
7. Fast track promoter approval – • Irish Management Companies have minimum net shareholder’s
within one week of application. are subject to tax of 12.5% on funds of €635,000, or equivalent
their trading income. Non- trading in another currency.
8. Extensive industry experience income will be taxable at 25%.
and expertise. • Promoter liability – Irish
• Double Taxation Treaties – 50 tax Promoters not legally responsible
agreements, 6 additional new for losses of funds, as long as
9. Location – optimum time zone to
treaties underway. due care has been provided.
ensure global coverage.
• Irish domiciled funds have access • The Irish custodian model
10. Only English speaking country in to the US double taxation treaty as required by the Financial
the Eurozone, Euro currency. where a fund is demonstrated to Regulator provides significant
be trading – this is a considerable comfort to investors. The
11. In Ireland today there are over advantage for exchange traded custodian will be directly liable
12,000 people employed directly funds. to the unit holders for any
in the investment fund industry. unjustifiable failure to perform
Other Distinguishing Factors its obligations or improper
12. Dedicated Shariah unit within the performance of them. Such
Irish Financial Regulator. • EU Savings Directive adopted in duties will also extend to the
Ireland. custodian’s appointment of any
• Irish risk management process sub-custodians, which is of
is based on guidance notes with particular importance to investors
built in flexibility. Risk monitoring where assets are likely to be held
for non-sophisticated funds in in various jurisdictions outside
Ireland is on a daily basis. In Ireland.
Ireland the risk management
3. How PwC Ireland can help? • Regulatory risk and compliance management.
• Assistance with continuing regulatory obligations.
Audit Services
Our audit approach is tailored to suit the size and nature • Responding to regulatory change.
of your organisation and draws upon our extensive
industry knowledge. In addition to the independent
Advisory Services
PwC also provides a full range of business advisory
audit we offer advisory services in the areas of financial
services for both large organisations and independent
reporting, corporate governance, regulatory compliance,
advisors entering the investment fund business. Our
independent controls and risk assessment.
business advisory services team can assist clients
in making strategic assessments of the investment
Tax & Legal Services
business, preparing business plans and economic
Our Tax and Legal Services formulates effective
analyses as well as advising on the structure of both
strategies for optimising taxes, implementing innovative
the investment advisor and the underlying fund. The
tax planning and effectively maintaining compliance.
team can also offer advice on systems and operational
needs, identifying and selecting outside vendors and
In recognition of the international tax issues to be
preparation of full documentation of policies and
considered in structuring funds, our specialised tax
procedures.
team works extensively with our global investment
management teams on an ongoing basis. Our market share
Irish-combined (Irish and non-Irish domiciled) market share
Regulatory Services
PwC has a dedicated regulatory and compliance service PwC
team to assist you with all aspects of financial services KPMG KPMG
regulation. The regulatory and compliance services 23% E&Y
team provides support and advice to help you identify, PwC Deloitte
55% E&Y
manage and control any existing and future regulatory 17% Other
risks. Our services can be broadly categorised under
three main headings:
Deloitte
Other 4%
• Market entry; feasibility studies, authorisation 1%
services, governance arrangements, compliance Source: Funds Encyclopaedia June 2008
frameworks, capital adequacy arrangements &
notification assistance.
PwC Investment Management Contacts - Ireland
Olwyn Alexander Jonathan O’Connell Robin Menzies
Tel: +353 1 792 8719 Tel: +353 1 792 8737 Tel: +353 1 792 8553
Email: olwyn.m.alexander@ie.pwc.com Email: jonathan.oconnell@ie.pwc.com Email: robin.menzies@ie.pwc.com
Pat Candon Marie O’Connor Tax & Legal Services
Tel: +353 1 792 8538 Tel: +353 1 792 6308
Email: pat.candon@ie.pwc.com Email: marie.o.connor@ie.pwc.com Jim McDonnell
Tel: +353 1 792 6836
Fiona De Burca Ken Owens Email: jim.mcdonnell@ie.pwc.com
Tel: +353 1 792 6786 Tel: +353 1 792 8542
Email: fiona.deburca@ie.pwc.com Email: ken.owens@ie.pwc.com Pat Wall
Tel: +353 1 792 8602
Patricia Johnston Tony Weldon Email: pat.wall@ie.pwc.com
Tel: +353 1 792 8814 Tel: +353 1 792 6309
Email: patricia.x.johnston@ie.pwc.com Email: tony.weldon@ie.pwc.com Pat Convery
Tel: +353 1 792 8687
Joanne Kelly Regulatory & Compliance Services Email: pat.convery@ie.pwc.com
Tel: +353 1 792 6774
Email: joanne.p.kelly@ie.pwc.com Deirdre McManus John O’Leary
Tel: +353 1 792 7356 Tel: +353 1 792 8659
Andrea Kelly Email: deirdre.mcmanus@ie.pwc.com Email: john.oleary@ie.pwc.com
Tel: +353 1 792 8540
Email: andrea.kelly@ie.pwc.com Advisory Real Estate
Vincent McMahon Andy O’Callaghan Enda Faughnan
Tel: +353 1 792 6192 Tel: +353 1 792 6247 Tel: +353 1 792 6359
Email: vincent.macmahon@ie.pwc.com Email: andy.ocallaghan@ie.pwc.com Email: enda.faughnan@ie.pwc.com
Damian Neylin Robin Menzies
Tel: +353 1 792 6551 Tel: +353 1 792 8553
Email: damian.neylin@ie.pwc.com Email: robin.menzies@ie.pwc.com
