Last Updated June 10, 2019

Law and Practice

Contributed By Walkers

Authors



Walkers is a global firm with ten substantive offices around the world. Its transactions often involve Cayman Islands, British Virgin Islands, Bermuda, Jersey and/or Guernsey legal matters, and it provides an integrated service to clients across its offices, legal systems and time zones. The finance and capital markets group in Ireland comprises a team of 23, including two listing agents. The group also includes four tax-advisers (including two tax partners) who support a number of practice areas and 16 dedicated capital markets fee-earners who spend the vast majority of their time advising on debt capital markets activity. In addition, the team works with asset finance, corporate, real estate and investment funds teams on multi-disciplinary, cross-border mandates. It is one of the largest dedicated debt capital markets teams in Ireland. The firm was a founding member of the Irish Debt Securities Association (IDSA) and sits on the Executive Council and Legal, Tax, CSP and Listing Sub-committees.

A person who is neither resident nor ordinarily resident in Ireland should not be subject to Irish tax on capital gains on disposals of listed or unlisted debt securities, unless the person is a company and is carrying on a trade in Ireland through a branch or agency in respect of which the securities are used or held.

For example, if a non-resident company is carrying on a trade in Ireland through a branch or agency dealing in debt securities, corporation tax at the rate of 12.5% would apply on any profit arising from the trade. The company in these circumstances would be required to register with the Revenue Commissioners of Ireland and self-assess through the Revenue on-line service (ROS). 

A charge to capital gains tax may also arise for non-Irish residents in respect of the disposal of certain specified Irish assets (ie, land and buildings in Ireland, exploration rights located in Ireland, goodwill of a trade carried on in Ireland and shares of a company that derives its value or the greater part of its value from land, buildings or exploration rights located in Ireland). Land, or an interest in land, for these purposes includes a loan secured on Irish land, eg, a mortgage. 

Walkers Global

The Exchange,
George's Dock, IFSC,
Dublin 1,
Ireland

+353 1 470 6600

+353 1 470 6601

info@walkersglobal.com www.walkersglobal.com
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Authors



Walkers is a global firm with ten substantive offices around the world. Its transactions often involve Cayman Islands, British Virgin Islands, Bermuda, Jersey and/or Guernsey legal matters, and it provides an integrated service to clients across its offices, legal systems and time zones. The finance and capital markets group in Ireland comprises a team of 23, including two listing agents. The group also includes four tax-advisers (including two tax partners) who support a number of practice areas and 16 dedicated capital markets fee-earners who spend the vast majority of their time advising on debt capital markets activity. In addition, the team works with asset finance, corporate, real estate and investment funds teams on multi-disciplinary, cross-border mandates. It is one of the largest dedicated debt capital markets teams in Ireland. The firm was a founding member of the Irish Debt Securities Association (IDSA) and sits on the Executive Council and Legal, Tax, CSP and Listing Sub-committees.

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