-
Business Consulting
Our Consulting team guarantees quick turnarounds, lower partner-to-staff ratio than most and superior results delivered on a range of services.
-
Business Risk Services
Our Business Risk Services team deliver practical and pragmatic solutions that support clients in growing and protecting the inherent value of their businesses.
-
Deal Advisory
Our experienced Deal Advisory team has provided a range of transaction, valuation, deal advisory and restructuring services to clients for the past two decades.
-
Digital Risk
Our Digital Risk team offer advisory and consulting solutions that give our clients peace of mind, clear value for money and an enhanced ability to react to cyber attacks.
-
Digital Transformation
Our Digital Transformation team work with business leaders to deliver efficient digital strategies and operating models that provide new or enhanced capabilities.
-
Forensic Accounting
Our Forensic and Investigation Services team have targeted solutions to solve difficult challenges - making the difference between finding the truth or being left in the dark.
-
Objectives and Key Results (OKRs)
Objectives and Key Results (OKRs) is a goal setting framework that helps teams, individuals and organisations set and track measurable goals.
-
People and Change Consulting
Our People & Change Consulting team help clients adapt to the changing nature of the workforce - how they attract, retain, engage, develop, deploy and lead their people.
-
Restructuring
Grant Thornton is Ireland’s leading provider of insolvency and corporate recovery solutions.
-
Outsourced Payroll
Our outsourced payroll teams become your dedicated payroll department, aiming to process your payroll in the most cost effective and compliant manner.
-
Outsourcing
Grant Thornton's reliable and cost-effective outsourcing services help you streamline your business operations by taking care of your workload.
-
Audit and Accounting Advisory
Our Audit and Accounting Advisory team takes the headache out of multi-jurisdictional audit compliance requirements as well as technical compliance with accounting standards and legislation for clients.
-
Business Process Outsourcing
Grant Thornton’s Business Process Outsourcing (BPO) team serves the needs of rapidly growing mid-tier multinationals operating out of Ireland and other hubs through the provision of services across the full range of finance functions.
-
Flexible People Solutions
At Grant Thornton, our Financial Accounting and Advisory Services (FAAS) department have a dedicated team that help finance functions maximise efficiency.
-
Global Compliance & Reporting Solutions
Our Global Compliance & Reporting Solutions service offering covers a full suite of compliance services including financial statement preparation and related filings, dual bookkeeping, direct and indirect tax, statistical returns and payroll.
-
Global Payroll Solutions
At Grant Thornton, we meet the challenges of our clients. Our Global payroll compliance service offering is tailored to meet all your payroll requirements through a single point of contact.
-
Actuarial
Our Actuarial team provides a comprehensive range of services to our insurance clients. From regulatory support for compliance to delivering specialist expertise in insurance & reinsurance.
-
Data Analytics
Our team helps to unlock the potential of data analytics within your organisation, allowing you to be more innovative, efficient and customer-centric than ever before.
-
Digital and Fintech
Our FinTech team are experts in technology and financial services and have a long track record of helping companies achieve sustained advantage.
-
Digital Risk
Our Digital Risk team offer advisory and consulting solutions that give our clients peace of mind, clear value for money and an enhanced ability to react to cyber attacks.
-
Financial Services Audit
Our Financial Services Audit team offers expertise and knowledge along with a horizontal approach to solving clients’ problems and queries.
-
Financial Services Consulting
We work closely with clients to understand their strategy and benchmark their performance against the very best international standards.
-
Financial Services Tax
Grant Thornton Ireland has a team of over 100 tax professionals providing advice to a diverse range of clients in the Financial Services sector.
-
FS Business Risk Services
Our FS Business Risk team have real experience of the financial services sector, through working within regulatory bodies or holding leadership positions in Risk, Compliance and Internal Audit functions.
-
Grant Thornton Pensioneer Trustees Limited
The Grant Thornton Pensioneer Trustee service can offer business owners, directors and employees the opportunity to manage their own retirement choices with full transparency.
-
Pension Audit
The Grant Thornton Pension Audit team has vast experience in managing schemes and preparing annual reports on them for clients.
-
Prudential Risk
Our industry leading Prudential Risk team works with clients on a range of areas including regulatory reporting, regulatory authorisations, on-site investigations and data quality assurance.
-
Quantitative Risk
Our Quantitative Risk team members bring a wide range of experience with many of them having backgrounds in banking, investment markets, regulation, professional practice, and academia.
-
Sustainability desk
We recognise that businesses are operating at different levels of maturity when it comes to sustainability, and pride ourselves on working with our clients to develop bespoke solutions to their needs.
-
Financial Accounting and Advisory Services (FAAS)
Our Financial Accounting and Advisory Services (FAAS) team designs and implements creative solutions for organisations expanding into new markets or undertaking functional financial transformations.
-
Grant Thornton Financial Counselling
Grant Thornton Financial Counselling (GTFC) comprises a team of highly qualified professionals who offer financial advice to individuals and corporates across a range of areas including savings, investments, pension planning, and inheritance and succession planning.
-
Inheritance Planning
Our services on Inheritance Planning mirror those on Succession Planning whereby the foundations of the plan are derived from meaningful conversations with those that wish to pass on or protect their asset base.
-
Personal Tax Compliance & Planning
The Grant Thornton Personal Tax team helps clients remain compliant and up to date with all of their tax obligations whilst ensuring that they are solutions driven and manage their finances in the most tax efficient way possible.
-
Succession Planning
We have extensive experience guiding our clients successfully through the succession process. This involves advice on both the qualitative and quantitative aspects of the process. While there is a business at the core of each succession plan we advise on, it is all predicated on understanding the people and their respective wishes.
-
Company Secretarial
Grant Thornton’s Company Secretarial team contains qualified Company Secretaries. Clients are assured that they will meet all of their obligations under the Companies Acts and other relevant legislation and regulations.
-
Corporation Tax
Our Corporation Tax team is made up of more than 40 highly experienced senior partners and directors who work directly with a wide range of domestic, international, and financial services clients. We place a strong emphasis on direct service to clients and we pride ourselves on the close personal relationships we build and the deep understanding of their businesses we develop
-
Employer Solutions
Attracting and retaining key talent, managing employment costs and ensuring compliance with complex tax rules presents one of the most serious challenges today for many businesses. You need to ensure that your business complies with increasingly complex tax legislation and can adapt to updated Revenue guidance in a cost-effective way and we are here to help.
-
Financial Services Tax
The Grant Thornton team is made up of experts who are fully up to date in terms of changing and evolving tax legislation. This is combined with industry expertise and an in-depth knowledge of the evolving financial services regulatory landscape.
-
Global Mobility Services
Grant Thornton Ireland offer a different approach to managing global mobility. We have brought together specialists from our tax, global payroll, people and change and financial accounting teams across Ireland and Northern Ireland, while drawing on the knowledge and insights of our global network of over 143 offices of mobility professionals to provide you with a holistic approach to managing global mobility.
-
International Tax
We develop close relationships with clients in order to gain a deep understanding of their businesses to ensure they make the right operational decisions. The wrong decision on how a company sells into a new market or establishes a new subsidiary can have major tax implications.
-
Tax Advisory
The Grant Thornton Tax Advisory team blends commercial experience and knowledge with tax expertise to advise clients on the full range of transactions including sales, mergers, restructurings and succession planning.
-
Tax Incentives
Our Tax Incentives team help clients access vital cash funding and tax incentives to enable them to achieve their growth ambition.
-
Transfer Pricing
Our Transfer Pricing team has extensive experience across all industries. They can assist clients in overcoming challenges and deliver sector specific, sustainable solutions.
-
VAT
Grant Thornton’s team of indirect tax specialists helps a range of clients across a variety of sectors including pharmaceuticals, financial services, construction and property and food to navigate these complexities.
-
Real Estate Tax Advisory
The Irish real estate market has experienced considerable change in recent years. This has resulted in the emergence of a number of challenges for investors, but has also brought about significant opportunities. With this in mind, taxation is now more than ever one of the key factors for real estate investors when appraising investments, financing methods and development structuring.
Finance Bill 2021 (the Bill), sets out the legislative changes required to implement many of the Budget day announcements on 12 October as well as a number of other measures not previously announced.
This article considers how these tax policy changes will impact taxpayers operating in the Irish real estate industry.
Non-Resident Corporate Landlords (‘NRCLs’)
From 1 January 2022, NRCLs will be subject to Irish corporation tax (as opposed to income tax) on Irish sourced rental profits and gains.
The current position is that where Irish real estate assets are held by a non-resident company, which does not carry on a trade in Ireland through a branch or agency, rental profits earned by the company will be subject to Irish income tax at a rate of 20%. This change will result in an increase in the rate of tax from 20% to 25%, which is aligned to the current position for Irish-resident companies.
The amendment also brings chargeable gains arising to non resident companies on the disposal of Irish property within the corporation tax regime. While this does not change the effective rate of tax on such gains (i.e. 33%), it will result in those companies being required to file and pay under the corporate tax regime and also falling within the potential scope of the new interest limitation rules.
Interest Limitation Rules (ILR)
In accordance with the first EU’s Anti-Tax Avoidance Directive (ATAD), Ireland has been required to introduce ILR for accounting periods commencing on or after 1 January 2022.
The ILR legislation is designed to combat attempts by multinational enterprises and other companies to obtain excessive tax relief for net interest and similar financing costs. The objective of these new rules is to ensure relief on financing costs is commensurate with the extent to which business activities are subject to corporation tax. The ILR achieves this by limiting the maximum tax deduction for net borrowing costs to 30% of EBITDA as measured under tax principles. This ignores any losses carried forward or back or group relief. There are certain exclusions and relieving measures which may apply but these must be considered on a case by case basis.
The cap is based on broadly defined “interest expenses” less “interest income”, referred to as “exceeding borrowing costs”.
Please refer to our insights on the ILR here for more detailed analysis on the rules. However, we have set out some of the key considerations for those operating in the Irish real estate market below:
- Long-term public infrastructure projects (as defined) are excluded from the scope of the ILR.
- Interest on legacy debt is excluded from the scope of the ILR. Legacy debt refers to debt, the terms of which were agreed before 17 June 2016 (this can be lost where there are subsequent modifications to the loan post this date).
- Financing costs such as arrangement fees, commitment fees etc. which are common in real estate financing are likely to be brought into the definition of “interest equivalent” and potentially subject to restriction.
- Disallowable interest costs may be carried forward to later years as a “deemed borrowing cost” and may be used in later years subject to total spare capacity in that later accounting period with no time limit in place. This may be relevant in real estate development projects whereby profit generation will not materialise until the asset is ultimately sold. However, there is a 60 month time limit on the use of the carried forward amounts as “total spare capacity”.
- The ILR provisions provide for a “group ratio” test where in situations where the group ratio exceeds 30% for an accounting period of a relevant entity (as defined), the relevant entity may make an election to calculate the allowable amount by reference to the group ratio, and not the 30% limit if found to be more beneficial.
The ILR rules are likely to have a significant impact for certain real estate businesses given the importance of debt financing and will add further complexity when considered with existing tax provisions. It is recommended that debt funded corporates (both domestic and international) consider the application of these rules and the potential impact to their tax charge in Ireland as soon as possible.
Stamp Duty
The Bill makes provision for a number of technical amendments to anti-avoidance provision Section 31E which previously brought forth the application of a 10% stamp duty rate in the case of certain bulk purchasing of residential property. These amendments include:
Zoned Land Tax
The Bill provides for the new Zoned Land Tax (ZLT) which will replace the existing vacant site levy and once implemented, will apply at a rate of 3% per annum on the market value of land that is within the scope of the regime. Broadly this is stated as land zoned as being suitable for residential development, that is serviced and that is not affected in physical condition by considerations which may impact the ability to provide housing on the land.
Unlike the vacant site levy, the ZLT will apply irrespective of the size of the site however, there are specific exclusions from the ZLT. While maps will be prepared and published by Local Authorities in advance of the commencement of the ZLT to identify zoned land within scope, the ZLT will be self-assessed and administered by the Revenue Commissioners i.e. landowners within scope will have to pay and file with Revenue on an annual basis from 2024 onwards. The due date for returns in respect of each period will be 23 May each year.
The aim of introducing the ZLT (similar to the vacant site levy) is not to generate tax revenue but rather to incentivise those who own serviced and undeveloped sites, that are zoned for residential use, to make them available and increase supply.
There will be a lead-in time of two years for land zoned before 1 January 2022 and a lead-in time of three years for land zoned after 1 January 2022. Provision is also made for a tax deferral subject to satisfying certain conditions (e.g., delays in construction or planning appeals) and for the repayment of tax where a site liable to the tax is later deemed to be unsuitable for development.
Transfer Pricing
The Bill makes two significant amendments to Ireland’s transfer pricing regulations effective from 1 January 2022.
The first of which provides for the exemption of non-trading domestic related party (‘Ireland to Ireland’) transactions from transfer pricing provisions which is important in the context of certain non trading transaction such as interest-free loans, rent-free use of property etc. The changes clarify that no consideration needs to be charged in a transaction for the exemption to apply. The legislation states that the supplier will benefit from the exemption if any consideration, if charged, would be liable to tax. From the perspective of the acquirer, they will also benefit if any consideration, if charged, would be deductible for tax purposes. In order to qualify for the exemption, certain anti-avoidance measures must be satisfied, including that the beneficiary from the exemption must be tax resident in Ireland, and it must involve a bona fide commercial transaction, and not for the avoidance of tax or part of a wider tax avoidance scheme
The second brings the Authorised OECD Approach (AOA) into Irish domestic law. The AOA attributes profits to an Irish branch or permanent establishment of a foreign company, that would have been earned at arm’s length, as if it were a separate and independent legal enterprise performing the same or similar functions under the same or similar conditions.
Anti Reverse Hybrid Rules
The Bill makes provision for the introduction of anti-reverse-hybrid rules as required in the second EU ATAD. The purpose of anti-hybrid rules is to prevent arrangements that exploit differences in the tax treatment of an instrument or entity under the tax laws of two or more territories to generate a tax advantage.
The anti-reverse hybrid rules bring certain tax transparent entities (e.g. Irish partnerships) within the scope of Irish corporation tax where the entity is 50% or more owned/controlled, as defined, by entities resident in a jurisdiction that regard the entity as tax opaque and, as a result of this hybridity, some or all of the hybrid entity’s profits or gains are subject to neither domestic nor foreign tax.
The broad nature of these rules requires detailed consideration by real estate groups operating in the Irish real estate market, particularly where interest bearing loans are provided by shareholders who are foreign associated entities.
Under the provisions, a “collective investment scheme”, as defined, will not be considered a reverse hybrid entity. A reverse hybrid mismatch outcome will also not arise where the participator is established in a territory that generally exempts profits and gains from tax in that territory or does not impose a foreign tax on such income.
Help to Buy Scheme
The Help to Buy Scheme (first introduced in Finance Act 2016) has been extended further in its current form to 31 December 2022. The aim of the scheme is to bolster the supply of first-time buyer homes. A full review of the scheme is due to take place in 2022.
Get in touch
For additional information on any of the foregoing provisions, please contact the below or your usual Grant Thornton contact.