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Budget 2017
Breakfast Briefing
12 October 2016
Fergal Cahill
Jean McCabe
President
Ennis Chamber
Newsletter
www.cahilltaxation.ie
@cahilltaxation
CTS | Cahill
Taxation Services
/cahilltaxation
Agenda
• Introduction
• Personal Taxes
• VAT & Excise
• Capital Taxes
• Farmer Taxation
• Business Taxes
• Anti-avoidance & Revenue Powers
• Conclusions
Main Points
• Further reform of USC
• Continued focus on entrepreneurship
• Property measures to tackle supply
• Measures to improve rural Ireland
• Measures to prepare Ireland for Brexit
• Conservative and constrained Budget, owing to economic
uncertainties.
Supplying the Housing Market
• Help-to-Buy Scheme
• Increase in CAT threshold
• Higher ceiling for rent-a-
room relief
• Increase in interest
deductibility for landlords
• Living City Initiative extended
• Home Renovation Incentive
Scheme extended
• Various infrastructure funds
established
Supporting the Rural Economy
• Earned Income Credit
• Income averaging
• Flat-rate Addition increase
• CGT exemption for bogs
• SEAI Energy Efficient
Equipment
• New low cost flexible loan
fund for farmers
• New Fishers Tax Credit
• Farm Restructuring Relief
extension
Getting Ireland Ready For Brexit
• Retention of 9% VAT rate
• FED & SARP extended
• Income Averaging for
farmers
• Increase in Earned Income
Credit
• CGT Entrepreneur Relief
• Establishment of “Rainy Day
Fund” in 2019
• Increase in Revenue Customs
Staff
• Revised Debt/GDP target of
45% - ability to borrow
Economic Picture
• Forecast growth at 4.2% for 2016.
• Forecast growth at 3.5% in 2017.
• Forecast growth at 3% in subsequent years.
• Deficit Target 0.9% of GDP in 2016 (target of 0.4% in 2017).
• Tax receipts almost €500m ahead of schedule in first 9
months of 2016. Slight wobble in August.
Economic Picture
• Unemployment levels decreasing:
• Currently 7.9%
• Expected 7.2% in 2017 (high of 15% in 2012)
• Forecast of 5.9% by 2020.
• Debt levels still high but reducing:
• Current Debt/GDP ratio is 93.8% (off a high of 120% in
2012)
• Projected Debt/GDP ratio of 71.96% by end of 2016.
Uncertain Times……
• New Government
• Apple EU State Aid Ruling
• Brexit
• Therefore, Budget conservative as a result
(€300m of taxation measures)
Personal Tax – More to do
• No changes of substance to our personal tax regime.
• Ireland is comparatively a low tax jurisdiction for
companies but a high tax jurisdiction for individuals.
• Entry level to marginal rate of 49% is only €33,800 – tax
rate on income over €70,000 is 52%.
• Much work needs to be done in the personal tax area
to make Ireland an attractive place to work and live.
• We have a very progressive tax system in Ireland.
Global Tax Analysis 2016*
€4,818
€4,032
€3,614
€3,200
€3,066
€2,522
€2,300
€1,696
€1,120
€600
€- €1,000 €2,000 €3,000 €4,000 €5,000 €6,000
Germany
France
Singapore
Sweden
Spain
Netherlands
United States
United Kingdom
Switzerland
Ireland
Tax paid at salary level of €18,000
*Based on information from KPMG & the Irish Tax Institute
Global Tax Analysis 2016*
*Based on information from KPMG & the Irish Tax Institute
€12,949
€10,476
€10,294
€8,813
€8,279
€7,654
€7,393
€6,954
€6,333
€6,040
€- €2,000 €4,000 €6,000 €8,000 €10,000 €12,000 €14,000
Germany
Netherlands
France
Spain
Sweden
Singapore
United Kingdom
Ireland
United States
Switzerland
Tax paid at a salary level of €35,800
Global Tax Analysis 2016*
*Based on information from KPMG & the Irish Tax Institute
€32,980
€30,351
€26,905
€26,482
€26,413
€24,351
€21,920
€21,351
€18,479
€13,040
€- €5,000 €10,000 €15,000 €20,000 €25,000 €30,000 €35,000
Germany
Netherlands
France
Ireland
Sweden
Spain
United Kingdom
Switzerland
United States
Singapore
Tax paid at salary level of €75,000
Global Tax Analysis 2016*
*Based on information from KPMG & the Irish Tax Institute
€70,815
€69,238
€66,212
€65,482
€62,395
€57,855
€57,759
€50,423
€41,959
€24,998
€- €10,000 €20,000 €30,000 €40,000 €50,000 €60,000 €70,000 €80,000
Netherlands
Sweden
Germany
Ireland
France
Spain
United Kingdom
Switzerland
United States
Singapore
Tax paid at salary level of €150,000
Caroline Kennedy
Budget 2017
Personal Taxes
Personal Taxes
• Decreases in rates of USC
• Increases in USC bands
• Changes to self-employed tax credits
• No change in Income Tax rates and tax bands
• Very modest changes overall
Earned Income Credit
• An earned income credit of €550 was introduced for self-employed taxpayers in Budget 2016.
• Budget 2017 increased earned income tax credit by €400 to€950.
• Applicable to taxpayers earning self-employed trading orprofessional income and to business owners who are ineligiblefor a PAYE credit on their salary income.
• Further increases in the credit expected in the coming years.The plan is to align credit with the employee tax credit(currently €1,650).
Tax Bands
TaxpayerTax Band
2016
Tax Band
2017Difference
Single/Widowed €33,800 €33,800 €-
Married
One Income€42,800 €42,800 €-
Married
Two Incomes€67,600 €67,600 €-
Single Parent€37,800 €37,800 €-
Tax Credits
TaxpayerTax Credits
2016
Tax Credits
2017Difference
Personal - Single €1,650 €1,650 €-
Personal - Married €3,300 €3,300 €-
Employee Credit €1,650 €1,650 €-
Single Person Child Carer €1,650 €1,650 €-
Home Carer €1,000 €1,100 €100
Age Credit – Single €245 €245 €-
Earned Income Credit €550 €950 €400
Fisher’s Tax Credit €- €1,270 €1,270
PRSI
2016 2017
PRSI Rate 4% 4%
Self-Employed PRSI 4% 4%
Employer PRSI 10.75% 10.75%
Employer Lower Rate
PRSI8.5% 8.5%
USC – PAYE Earners
Pre-Budget 2017 Post-Budget 2017
Band Rate Band Rate
Income < €13,000 Exempt Income < €13,000 Exempt
First €12,012 1% First €12,012 0.5%
€12,013 - €18,668 3% €12,013 - €18,772 2.5%
€18,669 - €70,044 5.5% €18,773 - €70,044 5%
Balance 8% Balance 8%
*USC rate for a medical card holder, over 66 years with income < €60k
reduced from 3% to €2.5%.
USC – Self-employed
Pre-Budget 2017 Post-Budget 2017
Band Rate Band Rate
Income < €13,000 Exempt Income < €13,000 Exempt
First €12,012 1% First €12,012 0.5%
€12,013 - €18,668 3% €12,013 - €18,772 2.5%
€18,669 - €70,044 5.5% €18,773 - €70,044 5%
€70,045 - €100k 8% €70,045 - €100k 8%
Balance 11% Balance 11%
Income Tax – Top Rate
2016 2017
Income Tax 40% 40%
PRSI 4% 4%
Universal Social
Charge*5.5% 5%
Total 49.5% 49%
*52% for individuals earning between €70,045.01 and €100,000.
*55% for self-employed earning over €100,000 (USC 11%).
Single Person Employee
Annual
Income
Net Wage
2016
Net Wage
2017Difference
€20,000 €18,448 €18,551 €103
€35,000 €28,442 €28,620 €178
€75,000 €48,518 €48,871 €353
€150,000 €84,518 €84,871 €353
Married Couple – One Income Employee
Annual
Income
Net Wage
2016
Net Wage
2017Difference
€20,000 €19,148 €19,251 €103
€35,000 €30,332 €30,510 €178
€75,000 €51,968 €52,321 €353
€150,000 €87,968 €88,321 €353
Married Couple – Two Incomes*
Annual
Income
Net Wage
2016
Net Wage
2017Difference
€20,000 €20,000 €20,000 €-
€35,000 €34,030 €34,206 €176
€75,000 €59,409 €59,789 €380
€150,000 €97,036 €97,742 €706
*Assumes both spouses earn same income
Single Person – Self-Employed
Annual
Income
Net Wage
2016
Net Wage
2017Difference
€20,000 €17,007 €17,510 €503
€35,000 €27,342 €27,920 €578
€75,000 €47,418 €48,171 €753
€150,000 €81,918 €82,671 €753
When do we enter the tax doors (Single Person)?
Enter
PRSI at
€18,305Enter
Income
Tax at
€16,500Enter
USC at
€13,000
Deposit Interest Retention Tax
• Budget 2014 increased the rate of DIRT from 33% to 41% with effect from 1 January 2014.
• Budget 2017 has introduced a rolling reduction of 2% per annum for a period of 4 years until the rate of DIRT returns to 33%.
• Accordingly, the rate applicable from 1 January 2017 will be 39%.
Foreign Earnings Deduction
• Relief from income tax available to individuals who are
tax resident in Ireland but spend a significant amount
of time working in a “relevant state”.
• Budget 2017 has extended the FED until 2020.
• Budget 2017 has also expanded the definition of a
relevant state to include Colombia and Pakistan from 1
January 2017.
• In addition, the minimum number of days spent
abroad has been decreased from 40 to 30 per annum.
Special Assignee Relief Programme
• Relief from income tax available to individuals who are assigned from abroad to work in Ireland.
• Available to employees with income over €75,000.
• Relief in the form of a deduction for 30% of income over €75,000.
• Budget 2017 has extended the SARP for a further 3 years until 2020.
Budget 2017
Indirect Taxes
VAT
• No change in rates.
• Low rate of 9% for tourismsector retained.
• Flat Rate addition for farmersincreased from 5.2% to 5.4%.
Excise
• Increase of 50 cents on pack of 20 cigarettes.
• Relief from excise duty for beer produced by
microbreweries extended.
• No change to motor tax and fuel.
• Sugar tax flagged for 2018 in line with UK.
VRT
• VRT relief for the purchase of hybrid electric vehicles is
being extended to 31 December 2018.
• Relief for electric vehicles and motorcycles is being
extended to 31 December 2021.
• No changes to headline rates of VRT.
Sinéad Dooley
Budget 2017
Capital Taxes
Capital Acquisition Tax
ThresholdEffective 14 October
2015New Threshold
Group A €280,000 €310,000
Group B €30,150 €32,500
Group C €15,075 €16,250
CAT Rate 33% 33%
Note: Changes to Section 86 Dwelling House Exemption were
expected in 2016 but no changes were introduced.
Capital Gains Tax
• No change in the current standard rate of CGT of 33%.
• CGT Entrepreneur Relief:
• The reduced rate of 20% applying to the disposal in whole or inpart of a business up to an overall limit of €1m in chargeable
gains is being reduced further to 10%.
• The overall limit of €1m is expected to increase in future years.
• Will this mean transactions will be delayed until “future years”?
Capital Gains Tax
• How does one structure businesses that may be sold inthe future?
• Pros and cons to both personal ownership andcorporate ownership (to discuss later).
• We expect that the use of a holding company will stillbe prevalent given exemptions from CGT underSection 626B and the ability to extract dividends taxfree.
• However, a 10% rate of CGT is very attractive.
• When structuring a business from the outset, one needsto have one eye of the future to determine beststructure and weigh up the pros and cons.
CGT/CAT Rate in Ireland
2008 2017
CGT Rate 20% 33%
CAT Rate 20% 33%
Exemption from
parent to child€521,208 €310,000
CGT Retirement
Relief
Relief available
for any investor
over age 55
Age cap reduces
the incentive to
pass on business
after age of 66
Budget 2017
Property Measures
Help-to-Buy Scheme
• Rebate of income tax paid over the previous four tax years for
First-Time Buyers of a newly built home.
• Relief capped at 5% of purchase price up to a value of
€400,000 i.e. maximum relief of €20,000.
• The rebate for houses of €400,000 to €600,000 will be capped at
€20,000. No rebate will be paid on house purchases of over
€600,000.
• Mortgage applicants must apply for a mortgage of 80% of the
purchase price of the house.
Help-to-Buy Scheme
• The Minister stated that he discussed the scheme with the
Governor of the Central Bank who has agreed that any rebate
received will be reckoned in full in the calculation of the
deposit required to be eligible for a mortgage under the
Central Bank’s rules.
• The Scheme will apply to the purchase of newly built primary
residences by first time buyers from the 19th of July this year until
the end of 2019.
• Second hand properties are not included.
• Is it of benefit to returning emigrants?
Help-to-Buy Scheme
Couple 1 Couple 2 Couple 3
Purchase Cost €200,000 €400,000 €500,000
Income Tax Paid
(last four years)€40,000 €100,000 €120,000
Potential Rebate
(maximum of 5%
of €400,000)€10,000 €20,000 €20,000
Interest Relief – Rented Residential Property
• Currently, the deduction available for qualifying interestpayments is restricted to 75%.
• The restriction is being amended to 80% in 2017.
• It is planned that the restriction will decrease by 5% each year,such that a 100% deduction will be allowed by 2021.
• Budget 2016 increased the allowable deduction to 100% forproperties let to tenants in receipt of certain social housingsupport for a period of 3 years.
Living City Initiative
• Tax Relief currently available to owner-occupiers who refurbish
residential properties in cities.
• Applies to ‘special regeneration areas’ in the centres of Dublin,
Cork, Limerick, Galway, Waterford and Kilkenny.
• Deduction of 10% of qualifying expenditure over 10 years.
• Deduction available against Total Income.
• Commercial properties – tax relief over a 7 year period by way
of accelerated capital allowances of 15% (10% in year 7).
Living City Initiative
Budget Changes:
• The scheme is being amended to include landlords.
• The restriction for residential applicants’ that the
property was previously used as a dwelling is being
removed.
• The limit on the floor size of the property and the
minimum amount of qualifying expenditure is being
increased.
Other
Home Renovation Incentive Scheme (“HRI”) Scheme
• The HRI Scheme is being extended by two years to 31 December 2018.
Rent-a-Room Relief
• Currently, an individual can receive an income tax exemption for letting out a room or rooms in their PPR up to a maximum limit of €12,000.
• The ceiling for the exemption is now being increased to €14,000 from 2017 onwards.
Stamp Duty
• No changes introduced tostamp duty.
• Residential at 1% (2% wherepurchase price exceeds €1m).
• Commercial at 2%.
Budget 2017
Farmer Taxation
Capital Allowances
• Currently, companies are entitled to acceleratedcapital allowances for energy efficient equipment.
• "The aim of this scheme is to help Irish businesses of allsizes, not only to reduce their energy use, but cruciallyto save money."
Minister of Communications, Energy and Natural Resources
• The scheme of accelerated capital allowances isadministered by the Sustainable Energy Authority ofIreland (“SEAI”).
• SEAI maintain a register of eligible products.
• Extensive list of products listed on www.seai.ie
Capital Allowances
• Capital allowances are typically available at a rate of 12.5%over 8 years.
• Where qualifying energy efficient equipment is acquired,100% of the expenditure qualifies for capital allowances inthe year the equipment is acquired.
• The Budget has extended the scheme to sole trades for2017.
• The scheme should therefore be attractive to farmerslooking to upgrade equipment in 2017.
Capital Allowances
Example 2016 2017
Qualifying Cost €10,000 €10,000
Capital Alls Year 1 12.5% 100%
Year 1 €1,250 €10,000
Tax Saving Year 1 €650 €5,200
Capital Alls Years 2 – 8 €8,750 € -
Tax Saving Year 2 – 8 €4,550 € -
A sole trader, liable to income tax at the marginal rate of 52%,
purchases energy efficient equipment for €10,000
Income Averaging
• A farmer can base his/her taxable profits in any one year on the
average of his/her profits over the previous 5 years (previously 3
years).
• Once a farmer opts for averaging, it is difficult (and often penal) to
opt out of averaging.
• In difficult years, a farmer’s assessable profits based on averaging
may be greater than actual profits in that year.
• In recognition of the fact that 2016 has been a particularly difficult
year for farming, the Budget has introduced an “opt out” in a
single year of unexpectedly poor income.
• Details awaited in the Finance Bill.
Income Averaging
Example Option 1 Option 2
Average Profits €30,000 €30,000
Profit 2016 €12,000 €12,000
Decision 2016 “Averaging” “Opt Out”
Assessable 2016 €30,000 €12,000
Assessable 2017 (et
seq)€30,000 €37,000
Capital Gains Tax
Raised Bogs
• Payments under the new raised bog restoration incentivescheme to relevant owners and rights holders of raised bogswill be exempt from CGT.
• The measure is intended to assist with the restoration ofselected raised bogs in the country, in line with the ActiveRaised Bog in Ireland’s Special Area of ConservationNetwork project which has recently been approved by theEuropean Commission. The project is reported to be worthover €5.4m and will run from 2016 to 2020.
Farm Restructuring
• Relief from CGT for disposals of farm land where the
proceeds are reinvested in new farm land within 24 months.
• Requires certification from Teagasc.
• Applied to sales between 1 January 2013 and 31 December
2016.
• Budget announced an extension to the relief from CGT until
31 December 2019.
• Limited application e.g. a farmer living in Clare but with a
farm in, say, Tipperary, could qualify for the relief if he sells
the land in Tipperary and re-invests the proceeds in
purchasing a farm in Clare.
VAT
• Flat Rate Addition is being increased from 5.2% to 5.4%
• Increase in number of farmers registered for VAT e.g. a
farmer with property may have to register for VAT.
• Once registered for VAT, the farm sales become
chargeable to VAT (at a rate of 5.4%).
• Increased number of Revenue audits into VAT
registered farmers.
• There are pros and cons to VAT registration for farmers.
Budget 2017
Business Taxes
Today’s Sponsor
€13bn
EU State Aid Findings
Apple Sales International
• Sales & Marketing – HO
• Distribution – HO
• Manufacturing - Ireland
Apple Sales International
• Irish Incorporated Company
• But not resident anywhere
• Three Divisions
Apple – EU State Aid Findings
• How were manufacturing division profits taxed inIreland?
• Submission to Irish Revenue to attribute taxable profitsto Irish “branch”.
• Cost plus model agreed – very prevalent at the time
• Agreement to tax manufacturing profits on a cost plus10%
Apple – EU State Aid Findings
Example:
• Irish Manufacturing operation taxed in Ireland on a cost plus 10% basis.
If costs are €100m, taxable profits in Ireland are €10m taxed at 12.5%
Tax Liability €1.25m
• What happened after 1991? Apple got BIG!
0
50
100
150
200
250
300
350
400
450
500
Marketing Distribution Manufacturing
Apple Sales International –Profits 1991 - 2015
Apple – EU State Aid Findings
• Problem was that sales and distribution profits went through
the roof.
• However, manufacturing costs in Cork only increased
modestly.
• Therefore, the profits attributable to the Cork branch were
disproportionally low.
• Therefore, the effective tax rate in Apple Sales International
was only 0.005%.
• Majority of profits not taxed anywhere. EU found that “Head
Office” existed on paper only.
Apple – EU State Aid Findings
• In retrospect, the 1991 treatment looks completely out of
proportion.
• However, at the time it was agreed “it was fine”.
• Should the terms have been reviewed some time between
1991 and 2016? YES
• It was reviewed in 2007 but no changes were made.
• The structure was eventually changed in 2015 but the EU
had already commenced its State Aid review.
What if Ireland loses the Appeal?
• How will Revenue collect €13bn from Apple?
• Will they seek a judgement?
• Will they send the Sheriff?
Ireland’s Corporate Tax Regime – Where are we?
• Where does this leave our 12.5% corporation tax rate?
• Is it at risk?
• Brexit
• What is the biggest threat to our 12.5% rate?
Ireland’s Corporate Tax Regime – Where are we?• The Minister used the Budget as an opportunity to provide an
update on Ireland’s International Tax Strategy.
• Maintenance of 12.5% rate remains the corner stone of Ireland’s
corporate tax strategy.
• Introduction of a Knowledge Development Box in Finance Act 2015
– rate of 6.25% for R&D profits.
• Ireland is actively participating in the OECD’s BEPS project –
Country by Country reporting introduced in 2015. Our transfer
pricing rules will be brought into line.
• Anti-Tax Avoidance Directive agreed in June – “hybrid
mismatches”, interest deductibility rules and Controlled Foreign
Company rules.
Ireland’s Corporate Tax Regime – Where are we?
• Ireland participating in a lot of different programmes aimed at
aggressive international tax planning.
• Exchange of Information between participating countries.
• Mandatory disclosure of aggressive tax schemes.
• Directive on Administration Cooperation – tax transparency
amongst EU States.
• Anti Money Laundering Rules
• Companies (Accounting) Bill 2016 – non disclosure structures
adversely affected. More far-reaching than expected
(transparency).
• Tax Treaties – negotiating and updating.
Budget 2017
Anti-Avoidance & Revenue Powers
Section 110 Companies
Taxation of Irish Rental Income Rate
Individual 50% - 55%
Companies 25% - 40%
Non Resident Company 20%
Section 110 Company 0%
Section 110 Companies
S 110
CompanyVulture
funds
Bank
€400mLoan Interest
payable
Caymans
€400m
Tax: ca. €100m+
Taxable Profits: €400m €0
Section 110 Companies
• A Section 110 company is a special purpose vehicles (SPVs)
established in Ireland to securitise assets.
• Perceived misuse of S110 by companies set up to hold distressed
loans and mortgages to avoid paying tax on Irish property related
transactions.
• 'Specified Property Business' excluded from benefits of S110 status.
• Lots of airplay in media on the use of these structures.
• Draft legislation already published – financial sector not happy with
draft wording.
• Final legislation awaited in Finance Bill.
• Will Revenue review existing S110 companies?
Revenue – Offshore Evasion
• Budget announced targeted compliance interventionsagainst those engaged in offshore tax evasion.
• Programme will use “advanced analytics techniques” to therange of new data sources available through FATCA, EUand OECD exchange of information initiatives.
• New legislation will be published to encourage “qualifyingdisclosures”.
• Deadline for making disclosures will be 1 May 2017.
• Introduction of a strict liability offence for failure to returndetails of offshore accounts or other assets.
• Panama Papers
Revenue Resources
• Announcement of increase in resources by 50.
• Targeted interventions.
• Increase in audit and investigation activities.
• Increase in “real time” interventions – catch it before ithappens.
• Enhancing IT systems capacity for data matching and dataanalytics.
• Consumption behaviour models.
• LPT register – rental income being trapped.
Budget 2017
Conclusions
Tax Rates
“Good Rates”
25% 19% 12.5% 10% 3.3% 0%
55% 51% 49.5% 41% 40% 33%
“Bad Rates”
Tax Rates
“Good Rates”
25% 19% 10% 3.3% 0%
55% 51% 49.5% 41% 40% 33%
“Bad Rates”
Trading
Tax Rates
“Good Rates”
19% 12.5% 10% 3.3% 0%
55% 51% 49.5% 41% 33%
“Bad Rates”
Surcharge
Investment
Income
Tax Rates
“Good Rates”
25% 19% 12.5% 10% 3.3% 0%
55% 51% 49.5% 41% 40%
“Bad Rates”
CGT &
CAT
Tax Rates
“Good Rates”
25% 19% 12.5% 10% 3.3%
55% 51% 49.5% 41% 40% 33%
“Bad Rates”
Retirement
Relief
Tax Rates
“Good Rates”
25% 19% 12.5% 3.3%
55% 51% 49.5% 41% 40% 33%
“Bad Rates”
Section
626B
Entrepreneur
Relief
Structuring Businesses
Personal or Corporate Ownership?
Company
OR
Conclusions
On the positive side:
• Continued reform of USC
• Reduction in marginal rate of tax for middle income earnersto 49% positive
• Taxation reform for self-employed welcome – a lot more todo.
• CGT Entrepreneur Relief
Conclusions
On the negative side:
• Capital Acquisitions Tax rate of 33% - too high
• Capital Gains Tax rate of 33% - too high
• CGT Entrepreneur Relief – should have went further. Will hisannouncement delay sales until 2018?
• Entry level to top rate still too low at €33,800
Disclaimer
This report is confined to the Irish tax implications for the transaction anddoes not address any other tax or non-tax matters.
Our report is based on our interpretation of what we consider to be therelevant Irish tax law and Revenue practices as of the date of thispresentation. It is understood that we have no responsibility to updatethis report for any changes in tax law or Revenue practices which occurafter today’s date. In common with any complex transaction such as this,where the interpretation of legislation is involved, no guarantee is giventhat the Revenue authorities or a court will not take different opinions tothose expressed in this presentation.
Our opinion is based on our understanding of the transaction as outlinedabove and how the transaction is to be implemented and administered.Clearly, any failure to implement the transaction in the manner intendedand any change to the proposed investment structure could havedifferent tax consequences and/or adverse tax consequences.
Our report is based on the background documentation and propertyvaluations provided and we have not enquired into the accuracy orotherwise of the information set out therein.
This report is solely for the use of the parties to the transaction and theiradvisers, and solely for the purposes of this transaction. It may not begiven to or relied upon by any other party.
TAX SPECIALISTSTAX EXPERTS
Suite 2 Aras Smith O’Brien
Bank Place, Ennis,
Co. Clare, Ireland.
V95 P48D
n +353 65 684 0630
p +353 65 684 0631
www.cahilltaxation.ie
Contact us:
www.cahilltaxation.ie
