your business in ireland – the competitive european location for international shipping services Over 1,200 international companies have chosen Ireland as their preferred location. Isn’t it time you found out about the opportunities for your business in Ireland?
Marine
Mar 30, 2016
A guide to Marine Business in Ireland
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your business in ireland –the competitive european location for international shipping servicesOver 1,200 international companies have chosen Ireland as their preferred location. Isn’t it time you found out about the opportunities for your business in Ireland?
www.imdo.ie
The attractions Ireland has to
offer your business are presented
in the following sections.
We invite you to take a look and
assess for yourself the opportunities,
business environment, and
advantages available by joining
our maritime cluster sector.
Then decide whether your company
wants to emulate the success
achieved by over 1,200 global fi rms
based in Ireland.
Doing Business in Ireland
welcome
Irish Ship Finance
Irish Tonnage Tax
Taxation Environment
www.imdo.ie
Welcome to The Irish Maritime Development Offi ce (IMDO)
I’m delighted to welcome you to our electronic information brochure which I believe will provide you with a succinct overview of the role and support services provided by the IMDO to Industry, Government and the wider Irish economy.
The Irish shipping services sector directly
employs just under 10,000 maritime professionals
across a multifaceted range of industries, from marine
commerce, fi nance, banking, management, shipowning
and shipbroking to short sea services, maritime
logistics, port industries and maritime education.
The IMDO development team engage and work
with national and international companies on a daily
basis both in Ireland and overseas. Our interface with
industry enables us to convert our market intelligence
into consistent, informed, expert policy advice to the
Government on issues and matters impacting on the
development and future of the sector.
The i-bro will provide you with a direct interactive
platform to access and engage further with IMDO
services. The IMDO team and I look forward to
supporting your business in Ireland.
Yours sincerely,
Glenn Murphy, Director.
dear user,
www.imdo.ie
Welcome to The Irish Maritime Development Offi ce (IMDO)
The Irish Maritime Development Offi ce (IMDO)
The Irish Maritime Development Offi ce (IMDO) was established by statute in December 1999 and commenced operations in July 2000.
It is incorporated within the Marine Institute and based
in Dublin. The offi ce is Ireland’s dedicated development,
marketing, and promotional agency for the shipping,
ports and shipping service sectors.
The IMDO has a legislative mandate that includes
amongst its statutory mandate the following functions:
To advise the Minister for Transport on the •
development and the co-ordination of policy in the
shipping and shipping services sectors, so as to
protect and create employment.
To advise the Minister on development and co-•
ordination of policy and to carry out policy as may
be specifi ed by that Minister relating to the Ports and
Ports services sector.
To promote and assist the development of Irish •
shipping and the Irish shipping services and seafarer
training.
To support and market the shipping and shipping •
services sectors.
To carry out policy as may be specifi ed by the •
Minister relating to the shipping and shipping services
sectors.
Welcome to The Irish Maritime Development Offi ce (IMDO)
www.imdo.ie
In this context “shipping services” is deemed to include:
Ship Management •
Technical Management •
Commercial Management •
Crew Management •
Port Activities & Logistics •
Ship Finance and Mortgages •
Marine Insurance •
Maritime Legal Services •
Ports •
Ports services •
Ship Broking •
Ship Chartering •
Short Sea Shipping. •
www.imdo.ie
Doing Business in Ireland
Doing Business in Ireland
Section 1.1 Section 1.2 Section 1.3 Section 1.4
Doing Business in Ireland
1.1
www.imdo.ieSection 1.1 Section 1.2 Section 1.3 Section 1.4
The Irish government has been committed to the development of the maritime transport sector through direct investment and the introduction of various incentives for training, employment, and business including the following:
The establishment of a dedicated maritime •
development agency, the IMDO in December 1999.
The introduction of Irish tonnage tax in 2002.•
Social insurance refunds to Irish companies to •
encourage the employment of seafarers.
Seafarers Additional Income Tax Relief.•
An investment of €58 million in the National Maritime •
College of Ireland.
Cost neutral training of deck offi cers, engineers •
and ratings funded through the innovative ISEAS
grant scheme.
maritime industry development
Doing Business in Ireland
1.1
www.imdo.ieSection 1.1 Section 1.2 Section 1.3 Section 1.4
Over 50% of people employed in the Irish Marine Sector work in Maritime Transport.
Total employment was estimated at 8,300 in Maritime •
Transport services and 14,000 when other direct
transport services were included.
The maritime services sector contributed to more •
than 50% of the combined direct turnover of
companies employed in the sector and average
employee turnover was estimated as €210,000.
The shipping sector also had the highest economic •
output and the highest economic employee multiplier
of all of the marine sectors.
Ireland is now one of the top 15 ship fi nance locations •
in the world.
Doing Business in Ireland
www.imdo.ieSection 1.1 Section 1.2 Section 1.3 Section 1.4
1.2
Ireland has one of the youngest populations in Europe with over 36% under the age of 25 years.
Almost 1 million people are in full-time education •
in Ireland.
According to the IMD World Competitiveness •
Report 2007, Ireland’s educational system scored
highest in the world for meeting the needs of a
competitive economy.
Ireland is in the enviable position of having a •
healthy and growing number of applicants for
seafaring training.
Ireland is one of the few European countries still •
training and placing ratings albeit aboard specialist
vessels requiring a high level of boatmanship skills.
The National Maritime College of Ireland (NMCI) •
is one of the world’s premier seafarer training
facilities with state-of-the-art simulator technology
at its disposal.
Through the Irish ISEAS fund the Irish government •
has made training cost neutral for shipping fi rms
wishing to take on NMCI cadets.
The Irish government has also been investing heavily •
in career training for offi cers and engineers wishing
to further their education.
labour market development
Doing Business in Ireland
www.imdo.ieSection 1.1 Section 1.2 Section 1.3 Section 1.4
1.3
In 2007 the Irish government launched its second six-year National Development Plan.
The government is investing over €184 billion to
2013 in social and economic infrastructure including
investments in the following areas:
€54.6 billion for investment in economic infrastructure•
€49.6 billion for social inclusion measures •
(children, people with disabilities, etc.);
€33.6 billion for social infrastructure •
(housing, health, justice, etc.);
€25.8 billion for human capital •
(schools, training, higher education, etc.)
€20 billion for enterprise, science and innovation. •
infrastructural investment
Doing Business in Ireland
www.imdo.ieSection 1.1 Section 1.2 Section 1.3 Section 1.4
In addition to the governments capital investment in education under the National Development Plan 2007-2013) the Irish Government announced in June 2006, a new Strategy for Science, Technology and Innovation, involving an investment of €8.2 billion over the next seven years.
The strategy aims for:
A doubling of postgraduates, with 1,000 PhDs every •
year by 2013 and a further 315 postgraduates in the
humanities and social sciences.
Five main areas of the economy will be opened up for •
hugely enhanced R&D - agri-food, marine industries,
energy, healthcare and the environment.
To attract, develop and support enterprise funding •
forms through the provision of corporate tax credits
for research and development and one of the most
attractive jurisdictions in the world for intellectual
property taxation.
innovation, research & development
1.4
www.imdo.ie
Irish Tonnage Tax
Irish Tonnage Tax
Section 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
Irish Tonnage Tax
2.1
www.imdo.ieSection 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
Irish Tonnage Tax is a unique and powerful incentive. It is based on a notional profi t taxed at a 12.5% corporation tax. This incentive offers an unrivalled taxation environment where you will benefi t from:
Flexibility to invest and to choose the methods of •
fi nancing most suitable to your company
Certainty regarding your company’s annual tax liability•
Clarity in terms of how it affects your company’s •
fi nancial structure
Competitiveness in a global marketplace where rivals •
seek out every cost advantage
Compatibility with the fi scal regimes of other •
countries. Ireland has an excellent network of tax
treaties primarily with EU and OECD countries.
why irish tonnage tax?
Irish Tonnage Tax
www.imdo.ieSection 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
The shipping industry operates complex corporate structures and complicated business relationships. The Irish administration recognises this and the tax is administered by the Revenue Commissioners-Incentives Branch so that you can discuss your business plan in a supportive environment.
Shipowners, Bareboat Charterers and Ship Managers
qualify for Irish tonnage tax if they:
Operate qualifying ships•
Are within the charge to Irish Corporation Tax•
Undertake the strategic and commercial •
management of those ships in Ireland.
who qualifi es?
2.2
Irish Tonnage Tax
www.imdo.ieSection 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
2.3
The Irish tonnage tax is a fl exible and friendly regime that covers income from a broad range of activities including the following:
Carriage of Passengers and Cargo.•
Ancillary Income ie. income from transport provided •
for non–tonnage tax activities. cable–laying diving
support, construction work, etc.
Towage, Salvage and Marine Assistance.•
Chartering.•
Ship Management Activities & Ship Managers •
can qualify.
Commercial Management and Other Activities.•
Provision of Services and Goods on Board.•
Franchise Income.•
what qualifi es?
Irish Tonnage Tax
www.imdo.ieSection 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
Ultimately it means that most companies generating profi t can avail of a:
Vastly reduced tax bill, a bill that has no relationship •
to the real profi ts generated by the company.
A tax bill that alters only when the relevant fl eet •
tonnage changes.
PLC’s can benefi t by announce high profi ts without •
a correspondingly high tax liability, simplifying tax
planning, reaping all the benefi ts of shareholder
value and achieving greater earnings per share,
and the resulting possibilities to access new fi nance
and investment.
Essentially, if you operate a commercial merchant •
seagoing vessel, it qualifi es.
The Irish Tonnage Tax regime will allow your company •
to benefi t from a broad range of income.
Extend Your Time in Tonnage Tax: you can elect to •
stay in the Irish Tonnage Tax for a further 10 years
AT ANY TIME while in the regime.
A Euro Economy.•
An Excellent Network of Double Taxation Treaties.•
how will irish tonnage tax affect your tax bill?
2.4
Irish Tonnage Tax
www.imdo.ieSection 2.1 Section 2.2 Section 2.3 Section 2.4 Section 2.5
Calculating you tax bill could not be easier. The following table lists the ‘Fixed profi t per day’ rate.
Take your vessels net tonnage and apply the rates •
according to the formula provided.
When you have your notional ‘profi t’ fi gure apply •
Ireland’s standard corporation tax rate of 12.5%.
You now have your tax bill.•
Fixed Profi t Rates Fixed profi t per day
Scale of charges based on vessels
net tonnage
For each 100 tons up to 1,000
net tons€1.00
For each 100 tons between 1,000
and 10,000 net tons€0.75
For each 100 tons between 10,000
and 25,000 net tons€0.50
For each 100 tons above 25,000
net tons€0.25
calculating your tonnage tax
2.5
www.imdo.ie
Irish Ship Finance
Irish Ship Finance
Section 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
Irish Ship Finance
3.1
www.imdo.ieSection 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
Ireland is possibly Europe’s most stable, effi cient, and well- regulated fi nancial services environment. The country has a breadth of expertise that stretches across the fi nance spectrum and includes the following:
It is one of the world’s fastest growing locations for •
shipping mortgage fi nance.
70% of global aviation leasing is carried out in Ireland.•
30% of global fund management activity is managed •
from Ireland.
Ireland is one of the leading jurisdictions for specialist •
shipping structured fi nance.
The world’s fi rst maritime securitisation was •
structured out of Ireland.
Ireland’s international ship fi nance portfolio has •
grown from a small local focus to approximately
€3bn in 5 years.
market development
Irish Ship Finance
www.imdo.ieSection 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
Ireland has become one of the world’s fastest growing locations for Debt fi nancing entering the Top 15 global locations for ship fi nancing in 2008.
Debt fi nancing is offered by a range of banks dealing
across a broad range of sectors from large bulk,
container, tanker and LNG to Offshore supply, standby,
etc. Irish based banks also specialise across a range of
deal sizes.
3.2
debt fi nancing in ireland
Irish Ship Finance
www.imdo.ieSection 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
3.3
Ireland is one of the world’s global centres for big ticket leasing, fi nancing and administration. With customer focused government administration and service-oriented Exchange, it is the location of choice for bond issues and public listings.
Ireland, as a low tax EU member with and excellent •
range of tax treaties, is the location of choice for a
range of bond issues and securitisations.
From the world’s largest shipping mortgage •
securitisations to shipping bond issues to raising
of capital for containerships through securitisation,
Ireland is fast becoming the premier jurisdiction for
large structured fi nancing
As well as being the global centre for aircraft leasing, •
cross border fi nancing and leasing expertise extends
to many other asset classes including shipping.
Several structuring opportunities exist for assets •
leasing into Irish companies, particularly tonnage
tax companies.
structured fi nance and leasing
Irish Ship Finance
www.imdo.ieSection 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
3.4
Ireland is one of the world’s largest locations for fund management and administration. In 2007, the 12 largest Irish based investment fi rms managed a combined portfolio of €252 billion.
The Irish Stock Exchange is recognised globally as •
the stock exchange of choice for listing hedge funds,
there are signifi cant marketing advantages for raising
investment with an EU Exchange.
The worlds largest shipping hedge funds are listed on •
the Irish Stock Exchange including Clarkson Hedge
Funds and Russell Global Shipping Funds.
With over 30% of the world’s fund management •
occurring in Ireland, the ir is a wealth of advice and
expertise to draw upon.
funds in ireland
Irish Ship Finance
www.imdo.ieSection 3.1 Section 3.2 Section 3.3 Section 3.4 Section 3.5
3.5
Please visit our website to read up to date news
and information on Ireland’s shipping industry.
www.imdo.ie
latest market news
www.imdo.ie
Taxation Environment
Taxation Environment
Section 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
Taxation Environment
4.1
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
Ireland is been well-known for its positive and competitive commercial environment. The key to Ireland’s economic success story lies in a combination of:
Business-friendly government policies.•
General openness to new business.•
Positive taxation environment. •
ireland’s economic success
Taxation Environment
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
4.2
Ireland’s current standard-rate corporation tax regime is as follows:
12.5% for profi ts generated from Irish trades. •
25% for other profi ts. •
Where a company incurs tax losses, these are •
generally available for group relief or indefi nite carry
forward within the company. There are a range of tax
relief’s available in relation to intragroup transactions
These rates compare positively to the corporation
tax rates applicable in many other jurisdictions and
with EU average tax rates.
corporation tax rates
Taxation Environment
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
4.3
A new holding company regime has been introduced in Ireland, with effect from 2 February 2004, exempts capital gains arising to Irish resident companies on the disposal of substantial shareholdings in certain corporate subsidiaries.
The tax rate applicable, in the absence of this
exemption, would be 20%.
The new regime also allows for enhanced foreign tax
credit relief on dividend income repatriated to Ireland.
Onshore ‘pooling’ of dividend income is permitted when
calculating foreign tax credit relief on dividend income
from subsidiaries where the holding company owns at
least 5% of the ordinary share capital of the subsidiary.
In addition, unutilised excess foreign tax credits may
be carried forward within the holding company for an
indefi nite period.
holding company regime
Taxation Environment
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
4.4
Irish withholding tax may apply to cross border payments of dividends, interest and royalties.
However, there are numerous exemptions that may be
available under domestic Irish tax law or double taxation
agreements to eliminate such withholding taxes. Ireland
has an extensive and ever growing network of double
taxation agreements.
withholding taxes
Taxation Environment
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
4.5
There are tax incentives for businesses that develop and manage Intellectual Property Rights (“IPR”) through assignment, licence or otherwise. These include:
Tax exemptions for Irish resident ‘inventors’ receiving •
royalty income from certain qualifying patents, where
research and development work on the invention,
leading to the patent, was carried out in Ireland.
Stamp duty exemption for transfers of IPR, and •
related goodwill.
Tax credit for qualifying incremental research and •
development expenditure.
intellectual property
Taxation Environment
www.imdo.ieSection 4.1 Section 4.2 Section 4.3 Section 4.4 Section 4.5 Section 4.6
4.6
Ireland has a number of preferential tax regimes applicable to collective investment funds and securitisation.
The tax benefi ts in relation to investment funds include
the ability to roll-up the value of the fund tax-free,
and withholding tax and stamp duty relief. In relation
to securitisations, there is tax deductions for costs
including funding costs, and wide-ranging exemptions
from withholding taxes and stamp duty.
preferential fi nancial services rules
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