Ireland: Offshore Business Sectors
Licensing, Royalties and Franchising
Acquisition by the Irish company of the rights in the first place can usually be carried out without a stamp duty or transfer charge; and there are no thin capitalisation rules, so that capital duties will be minimal.
Ireland's extensive network of Double Tax Treaties will ensure that incoming revenues are normally free of withholding taxes. In some cases the tax treaty might have excluded payments destined for companies which don't pay 'normal' taxes; this problem has perhaps disappeared now that the 12.5% rate is in force, because it is the EU-accepted
In mid-2002 the UK government announced that as a result of the 12.5% corporation tax rate it would no longer automatically exclude Irish companies from operation of its CFC (Controlled Foreign Corporation) rules.