CrowleysDFK
All Roads Lead
to Ireland
WWW.CROWLEYSDFK.IE
Contents
01 02 03 04
About the Firm
Our International
Network
Our Partners
AboutUs
Ireland’s Economic &
Competitiveness Update
Why Invest in Ireland
InvestinginIreland
Our Sector Experience
Our Services
Case Studies
OurFDI &SMEExperience
Benefits of working
with Crowleys DFK
WhyWorkWithUs?
2
Foreign Direct Investment
Small & Medium-Sized Enterprises
Family-Owned Business
Public Sector
Technology
MarketsServed
Audit & Assurance
Tax
Advisory
Outsourcing
Service Areas
5 Partners
55 Staff
Resources Locations
At Crowleys DFK we never lose focus on clients’ objectives
CrowleysDFKinaSnapshot
Corporate tax
International tax
VAT
Transfer Pricing
R&D tax reliefs
IP structuring
Capital tax
Relevant Contracts Tax
IP structuring
Personal tax
Cork
5 Lapps Quay
Cork
Dublin
16/17 College Green
Dublin 2
3WWW.CROWLEYSDFK.IE 3
WWW.CROWLEYSDFK.IE
Managing Partner
James O’Connor
James has been
instrumental in developing
our membership of DFK
International.
Tax Services
Edward Murphy
Specialises in international
corporate structuring,
property transactions, VAT
and employment tax.
Audit & Assurance
Tony Cooney
Specialising in the areas of
audit, risk, governance and
compliance services.
Advisory Services
Colette Nagle
Secialises in business
advisory and outsourcing
services.
Particular experience
working with SME clients.
Business Consultancy
Vincent Teo
Specialises in strategic and
operational management consulting.
Plays a key role in inward investment
work, focusing on South East Asia.
Designer
4
joconnor@crowleysdfk.ie
https://ie.linkedin.com/in/jamesgoconnor
Meet our Partners
OurPartners
emurphy@crowleysdfk.ie
https://ie.linkedin.com/in/edwardmurphy2
tcooney@crowleysdfk.ie
https://ie.linkedin.com/in/cooneytony
cnagle@crowleysdfk.ie
https://ie.linkedin.com/in/colettenagle
vteo@crowleysdfk.ie
https://ie.linkedin.com/in/vincentteo
WWW.CROWLEYSDFK.IE 5
215 member
firms
DFK International (“DFK”) is a major international association of independent accounting firms and
business advisers that has been meeting the needs of clients with interests in more than one
country for more than 50 years.
Our DFK membership provides our clients with an integrated and robust global delivery
mechanism across the world.
Where DFK member firms work together on cross border assignments we operate as one team.
This is a powerful and important feature which save clients time, money and allow resources to be
best utilised.
5
420 offices
worldwide
Across 90
countries
worldwide
11,011
Partners and
staff
US$1.237bn
total fee
income
DFKInternational
Local Knowledge - Global Presence
ThefirmisanindependentmemberofDFKInternational
Ireland:OneoftheBestPlacesto
doBusiness
WWW.CROWLEYSDFK.IE 7
Ireland’sEconomicUpdate
Q1 2016
Among the leading
investments secured
during 2015
2015 was a record year for FDI. The number of
investments up 8%.
Number of investments won 213. 94 were from
companies investing in Ireland for the first time.
Total new jobs created in 2015 was 18,983.
Net jobs created was 11,833 – up 66% on previous
year.
Source: IDA Ireland
WWW.CROWLEYSDFK.IE 8
Ireland’sEconomicUpdate
Q1 2016
Fatest growing advanced
economy in the world
Labour market
recovery continues
Recovery is most clearly evident in the
labour market with employment having
increased in each of the last twelve
quarters.
The European Commission, the OECD
and the IMF all forecast that Irelnad will
continue it’s strong expansion from
2015 right into 2016.
201
4
5.2%
2014
4.3%
2016
6.2%
2015
3.5%
2017
Employment
grew 2.9%
between 2014
& 2015
Labour costs
relatively
stable since
2008. Up 4%
compared to
14% in the EU
Source: IDA Ireland
WWW.CROWLEYSDFK.IE 9
WhyIrelandasanInvestmentLocation?
Ireland’s performance as a hub for Foreign Direct Investment is unrivalled
Best Country in
Western Europe
to invest in
1st in the world
for availability of
skilled labour
1st in the world
for inward
investment by
quality and
value
1st in the world
for investment
incentives
In the top 10
most innovative
countries in the
world
Source: IDA Ireland
WWW.CROWLEYSDFK.IE 10
01 One of the lowest statutory corporate
rates in the world at 12.5%
02
Effective zero tax rate for foreign
dividends03
Attractive holding company regime
04
25% R&D tax credit plus R&D grants 05
A strong legal framework for
development, exploitation and
protection of Intellectual Property
rights
06
The world’s first OECD-compliant
Knowledge Development Box (Patent
Box) at a rate of 6.25%
WhyIrelandasanInvestmentLocation?
Ireland’s Tax Regime
CrowleysDFKForeignDirect
InvestmentExperience
WWW.CROWLEYSDFK.IE
We are proud of the reputation and long
term relationships we have built with
our Foreign Direct Investment clients
over the years.
We have particular experince working
with FDI clients in the SME and Family-
Owned Business sectors.
AtCrowleysDFKwehave
awealthofexperience
advisingandworkingwith
foreignSMEslookingto
locatetoIreland.
12
Our experienced team advise on how
best to structure Irish operations. We
work with clients in securing
Government funding and on dealing
with Irish tax and company obligations.
Once set up, we provide a full range of
compliance and advisory professional
services.
WWW.CROWLEYSDFK.IE
Initial Work
• Incorporation of new private limited
company
• Taxes registration for the purposes of
Corporation Tax, Employer Tax and
Value Added Tax (VAT)
• Assistance with opening of a Bank
account
• International tax planning and
structuring
• Tax efficient IP structuring
Annual ComplianceWork Advisory & Outsourcing Services
• Preparation of annual financial
statements
• Statutory audit of financial statements
• Corporation tax annual compliance
• Company secretarial compliance
• Provision of registered office
• R&D tax credits
• Management accounts and reporting
• Budgetary control
• Bookkeeping including the preparation
and filing of VAT Returns
• Payroll outsourcing
• Corporate finance
13
ServicestoFDIClients
01 02 03
WWW.CROWLEYSDFK.IE
Portfolio
In conjunction with our DFK USA colleagues and the clients lawyers, we
advised on the optimum corporate structure, with two main objectives of:
1. Qualifying for Ireland’s corporate tax rate of 6.25% available to
companies whose activities are within the remit of the Knowledge
Development Box (KDB) tax regime; and
2. Protecting ultimate anonymity of the US shareholders.
We also:
1. Assisted with locating office space in Dublin for the client to purchase.
2. Organised the taxes registration of the company and its non-resident
employees in Ireland.
Working with the US based Group CFO, we now:
1. Provide monthly payroll and management accounting services.
2. Ensure the company meets all its annual compliance and tax
obligations.
14
This New York based software
development company, referred to us by
a DFK USA firm, is an SME company with
gross revenues of €50m.
The company chose Ireland as its EU
base to develop a new suite of software
products.
SoftwareDevelopmentCompany
Lorem ipsum amet stetur
adipiscing elit. Nunc enim
sem, commoarhonc stamet,
elementum
After meeting with the company executives in Dublin, we assisted the
company with the following:
1. Forming the Irish company.
2. Registering the company for taxes.
3. Attending the initial on-site Irish Revenue Value Added Tax (VAT)
verification visit.
4. Providing payroll, VAT and management accounting services in addition
to the annual financial statements and corporate tax compliance
requirements.
We also provide the company with ad-hoc tax consultancy advices on
various matters including VAT and withholding taxes.
This Atlanta based data-hosting provider,
referred to us by our DFK USA
colleagues, required assistance in setting
up a European operation in Ireland
As well as the low corporate tax rate and
highly educated workforce, Ireland was
chosen because of the IP connection
speed required to deliver the
Infrastructure as a Service (IaaS)
solution to their customers.
DataCentreCompany
CaseStudies
WWW.CROWLEYSDFK.IE
Portfolio
Our first task was to advise the client in negotiating the purchase of a site
for the building of their manufacturing facility. This involved
recommending local expert lawyers and planning consultants.
On the corporate side we advised the client on the:
1. Tax advantages of transferring of Intellectual Property to Ireland and
the potential to re-charge to their other (non-US) companies.
2. R&D tax credits available.
3. Tax Capital Allowance available for the plant construction and fit-out.
4. Transferring pricing issues for inter-group transactions.
The Irish company is now formed and construction is due to be
completed at the end of 2016. We have been appointed to provide
ongoing monthly payroll, book-keeping and tax filing services as well as
preparing annual financial statements, statutory audit and consolidation
reporting to the parent company.
15
This Minnesota family-owned company,
with 18 production plants and sales
offices globally, wanted to locate to
Ireland for both commercial and family
reasons.
PlasticsEngineeringManufacturer
We advised the client on:
1. The corporate structure.
2. Share capital requirements.
3. Requirements to avail of Ireland’s low corporate tax rate at 12.5%.
4. Advised on dividend payments and any withholding tax
considerations.
Since forming the Irish entity and registering it for taxes, we:
1. Service the client with our in-house payroll and management
accounts bureau.
2. Advise on ad-hoc tax and queries.
3. Prepare and audit the financial statements and file the client’s
corporation tax returns.
A fast growing North American media
company wished to set-up a European
operation to further its expansion.
Working with our DFK colleagues, we
discussed with the client the advantages
of using Ireland as its EU base.
MediaPublications Company
CaseStudies
WWW.CROWLEYSDFK.IE
01
02
03
By having a dedicated team of tax experts we can
ensure that we are always on-hand to answer
crucial questions at the point when they are
needed.
Always available
At Crowleys DFK we have built our reputation on
our ability to deliver professional services based
our promises.
We will work closely with all of your key people to
ensure we understand what you need to achieve
from our relationship. This will then ensure we
always deliver on our promises.
Reputationthroughdelivery
16
We always deliver to our promises
WhyWorkWithUs
Subject matter experts
Our talented tax people are proven subject matter
experts in specialist tax areas including corporate
taxation, structuring of tax-based investments
withholding taxes and dividends.
WWW.CROWLEYSDFK.IE
ConnectWithUs
17
www.crowleysdfk.ie
Crowleys DFK
@CrowleysDFK
This publication is intended only as a general guide and should not be used as a substitute for professional advice.
Directors: James O’Connor Tony Cooney Edward Murphy Colette Nagle Vincent Teo
Crowleys DFK Unlimited Company trading as Crowleys DFK. Registered Office: 16/17 College Green, Dublin D02 V078. Company No. 393878
A member firm of DFK International a worldwide association of independent firms.
Registered to carry on audit work and authorised to carry investment business by the Institute of Chartered Accounts in Ireland (ICAI). Chartered
Accountants Ireland is the operating name of ICAI.
ContactUs
+353 01 6790800
www.crowleysdfk.ie
emurphy@crowleysdfk.ie
https://twitter.com/CrowleysDFK
https://www.linkedin.com/company/crowleys-dfk

Foreign Direct Investment

  • 1.
  • 2.
    WWW.CROWLEYSDFK.IE Contents 01 02 0304 About the Firm Our International Network Our Partners AboutUs Ireland’s Economic & Competitiveness Update Why Invest in Ireland InvestinginIreland Our Sector Experience Our Services Case Studies OurFDI &SMEExperience Benefits of working with Crowleys DFK WhyWorkWithUs? 2
  • 3.
    Foreign Direct Investment Small& Medium-Sized Enterprises Family-Owned Business Public Sector Technology MarketsServed Audit & Assurance Tax Advisory Outsourcing Service Areas 5 Partners 55 Staff Resources Locations At Crowleys DFK we never lose focus on clients’ objectives CrowleysDFKinaSnapshot Corporate tax International tax VAT Transfer Pricing R&D tax reliefs IP structuring Capital tax Relevant Contracts Tax IP structuring Personal tax Cork 5 Lapps Quay Cork Dublin 16/17 College Green Dublin 2 3WWW.CROWLEYSDFK.IE 3
  • 4.
    WWW.CROWLEYSDFK.IE Managing Partner James O’Connor Jameshas been instrumental in developing our membership of DFK International. Tax Services Edward Murphy Specialises in international corporate structuring, property transactions, VAT and employment tax. Audit & Assurance Tony Cooney Specialising in the areas of audit, risk, governance and compliance services. Advisory Services Colette Nagle Secialises in business advisory and outsourcing services. Particular experience working with SME clients. Business Consultancy Vincent Teo Specialises in strategic and operational management consulting. Plays a key role in inward investment work, focusing on South East Asia. Designer 4 joconnor@crowleysdfk.ie https://ie.linkedin.com/in/jamesgoconnor Meet our Partners OurPartners emurphy@crowleysdfk.ie https://ie.linkedin.com/in/edwardmurphy2 tcooney@crowleysdfk.ie https://ie.linkedin.com/in/cooneytony cnagle@crowleysdfk.ie https://ie.linkedin.com/in/colettenagle vteo@crowleysdfk.ie https://ie.linkedin.com/in/vincentteo
  • 5.
    WWW.CROWLEYSDFK.IE 5 215 member firms DFKInternational (“DFK”) is a major international association of independent accounting firms and business advisers that has been meeting the needs of clients with interests in more than one country for more than 50 years. Our DFK membership provides our clients with an integrated and robust global delivery mechanism across the world. Where DFK member firms work together on cross border assignments we operate as one team. This is a powerful and important feature which save clients time, money and allow resources to be best utilised. 5 420 offices worldwide Across 90 countries worldwide 11,011 Partners and staff US$1.237bn total fee income DFKInternational Local Knowledge - Global Presence ThefirmisanindependentmemberofDFKInternational
  • 6.
  • 7.
    WWW.CROWLEYSDFK.IE 7 Ireland’sEconomicUpdate Q1 2016 Amongthe leading investments secured during 2015 2015 was a record year for FDI. The number of investments up 8%. Number of investments won 213. 94 were from companies investing in Ireland for the first time. Total new jobs created in 2015 was 18,983. Net jobs created was 11,833 – up 66% on previous year. Source: IDA Ireland
  • 8.
    WWW.CROWLEYSDFK.IE 8 Ireland’sEconomicUpdate Q1 2016 Fatestgrowing advanced economy in the world Labour market recovery continues Recovery is most clearly evident in the labour market with employment having increased in each of the last twelve quarters. The European Commission, the OECD and the IMF all forecast that Irelnad will continue it’s strong expansion from 2015 right into 2016. 201 4 5.2% 2014 4.3% 2016 6.2% 2015 3.5% 2017 Employment grew 2.9% between 2014 & 2015 Labour costs relatively stable since 2008. Up 4% compared to 14% in the EU Source: IDA Ireland
  • 9.
    WWW.CROWLEYSDFK.IE 9 WhyIrelandasanInvestmentLocation? Ireland’s performanceas a hub for Foreign Direct Investment is unrivalled Best Country in Western Europe to invest in 1st in the world for availability of skilled labour 1st in the world for inward investment by quality and value 1st in the world for investment incentives In the top 10 most innovative countries in the world Source: IDA Ireland
  • 10.
    WWW.CROWLEYSDFK.IE 10 01 Oneof the lowest statutory corporate rates in the world at 12.5% 02 Effective zero tax rate for foreign dividends03 Attractive holding company regime 04 25% R&D tax credit plus R&D grants 05 A strong legal framework for development, exploitation and protection of Intellectual Property rights 06 The world’s first OECD-compliant Knowledge Development Box (Patent Box) at a rate of 6.25% WhyIrelandasanInvestmentLocation? Ireland’s Tax Regime
  • 11.
  • 12.
    WWW.CROWLEYSDFK.IE We are proudof the reputation and long term relationships we have built with our Foreign Direct Investment clients over the years. We have particular experince working with FDI clients in the SME and Family- Owned Business sectors. AtCrowleysDFKwehave awealthofexperience advisingandworkingwith foreignSMEslookingto locatetoIreland. 12 Our experienced team advise on how best to structure Irish operations. We work with clients in securing Government funding and on dealing with Irish tax and company obligations. Once set up, we provide a full range of compliance and advisory professional services.
  • 13.
    WWW.CROWLEYSDFK.IE Initial Work • Incorporationof new private limited company • Taxes registration for the purposes of Corporation Tax, Employer Tax and Value Added Tax (VAT) • Assistance with opening of a Bank account • International tax planning and structuring • Tax efficient IP structuring Annual ComplianceWork Advisory & Outsourcing Services • Preparation of annual financial statements • Statutory audit of financial statements • Corporation tax annual compliance • Company secretarial compliance • Provision of registered office • R&D tax credits • Management accounts and reporting • Budgetary control • Bookkeeping including the preparation and filing of VAT Returns • Payroll outsourcing • Corporate finance 13 ServicestoFDIClients 01 02 03
  • 14.
    WWW.CROWLEYSDFK.IE Portfolio In conjunction withour DFK USA colleagues and the clients lawyers, we advised on the optimum corporate structure, with two main objectives of: 1. Qualifying for Ireland’s corporate tax rate of 6.25% available to companies whose activities are within the remit of the Knowledge Development Box (KDB) tax regime; and 2. Protecting ultimate anonymity of the US shareholders. We also: 1. Assisted with locating office space in Dublin for the client to purchase. 2. Organised the taxes registration of the company and its non-resident employees in Ireland. Working with the US based Group CFO, we now: 1. Provide monthly payroll and management accounting services. 2. Ensure the company meets all its annual compliance and tax obligations. 14 This New York based software development company, referred to us by a DFK USA firm, is an SME company with gross revenues of €50m. The company chose Ireland as its EU base to develop a new suite of software products. SoftwareDevelopmentCompany Lorem ipsum amet stetur adipiscing elit. Nunc enim sem, commoarhonc stamet, elementum After meeting with the company executives in Dublin, we assisted the company with the following: 1. Forming the Irish company. 2. Registering the company for taxes. 3. Attending the initial on-site Irish Revenue Value Added Tax (VAT) verification visit. 4. Providing payroll, VAT and management accounting services in addition to the annual financial statements and corporate tax compliance requirements. We also provide the company with ad-hoc tax consultancy advices on various matters including VAT and withholding taxes. This Atlanta based data-hosting provider, referred to us by our DFK USA colleagues, required assistance in setting up a European operation in Ireland As well as the low corporate tax rate and highly educated workforce, Ireland was chosen because of the IP connection speed required to deliver the Infrastructure as a Service (IaaS) solution to their customers. DataCentreCompany CaseStudies
  • 15.
    WWW.CROWLEYSDFK.IE Portfolio Our first taskwas to advise the client in negotiating the purchase of a site for the building of their manufacturing facility. This involved recommending local expert lawyers and planning consultants. On the corporate side we advised the client on the: 1. Tax advantages of transferring of Intellectual Property to Ireland and the potential to re-charge to their other (non-US) companies. 2. R&D tax credits available. 3. Tax Capital Allowance available for the plant construction and fit-out. 4. Transferring pricing issues for inter-group transactions. The Irish company is now formed and construction is due to be completed at the end of 2016. We have been appointed to provide ongoing monthly payroll, book-keeping and tax filing services as well as preparing annual financial statements, statutory audit and consolidation reporting to the parent company. 15 This Minnesota family-owned company, with 18 production plants and sales offices globally, wanted to locate to Ireland for both commercial and family reasons. PlasticsEngineeringManufacturer We advised the client on: 1. The corporate structure. 2. Share capital requirements. 3. Requirements to avail of Ireland’s low corporate tax rate at 12.5%. 4. Advised on dividend payments and any withholding tax considerations. Since forming the Irish entity and registering it for taxes, we: 1. Service the client with our in-house payroll and management accounts bureau. 2. Advise on ad-hoc tax and queries. 3. Prepare and audit the financial statements and file the client’s corporation tax returns. A fast growing North American media company wished to set-up a European operation to further its expansion. Working with our DFK colleagues, we discussed with the client the advantages of using Ireland as its EU base. MediaPublications Company CaseStudies
  • 16.
    WWW.CROWLEYSDFK.IE 01 02 03 By having adedicated team of tax experts we can ensure that we are always on-hand to answer crucial questions at the point when they are needed. Always available At Crowleys DFK we have built our reputation on our ability to deliver professional services based our promises. We will work closely with all of your key people to ensure we understand what you need to achieve from our relationship. This will then ensure we always deliver on our promises. Reputationthroughdelivery 16 We always deliver to our promises WhyWorkWithUs Subject matter experts Our talented tax people are proven subject matter experts in specialist tax areas including corporate taxation, structuring of tax-based investments withholding taxes and dividends.
  • 17.
  • 18.
    This publication isintended only as a general guide and should not be used as a substitute for professional advice. Directors: James O’Connor Tony Cooney Edward Murphy Colette Nagle Vincent Teo Crowleys DFK Unlimited Company trading as Crowleys DFK. Registered Office: 16/17 College Green, Dublin D02 V078. Company No. 393878 A member firm of DFK International a worldwide association of independent firms. Registered to carry on audit work and authorised to carry investment business by the Institute of Chartered Accounts in Ireland (ICAI). Chartered Accountants Ireland is the operating name of ICAI. ContactUs +353 01 6790800 www.crowleysdfk.ie emurphy@crowleysdfk.ie https://twitter.com/CrowleysDFK https://www.linkedin.com/company/crowleys-dfk