The deal involves the financing the Celtic Interconnector, being developed by Ireland's EirGrid and its French counterpart, RTÉ, the first connection between Ireland and Europe's electricity grids. The project is being developed by EirGrid and RTÉ, underpinned by a competitive funding package including a €300m term loan from Danske Bank and a €200 million facility provided by BNP Paribas and Barclays.
Photo: [L-R] Brendan O'Donnell, Danske Bank Director Corporates & Institutions; Alistair Welch, Danske Bank Head of International Units & Country Manager Ireland; Mark Foley, EirGrid Group Chief Executive and Michael Behan, EirGrid Chief Financial Officer.
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This month's Editorial, titled "The history of finance", takes as an example the workings of the BEPS corporation tax regime announced in July by the OECD as a sign of a growing importance of the global regulatory and governance frameworks that Ireland as a small open economy exists and prospers within. There are philosophical debates around the efficacy of this process that lie at the core of our future.....
Details of the 239 Nominations for the 2023 annual Finance Dublin Deals of the Year Awards 2023. The shortlisted deals provide the most comprehensive analysis of the most significant deals across the finance ecosystem in Ireland in 2022.
Also: the state of play in global banking, following the jitters spurred by the collapse of SVB Bank, including fragility risks in certain areas, including the implementation (by the Fed) of money markets regulation; the important EU Sandbox initiative, welcomed by an Irish Central Bank Spokesman in a statement in Finance Dublin.
In the May issue of the Finance Dublin Irish Tax Monitor the Panel comments on the Government's proposed approach to implementing BEPS Pillar Two, including how it could bring heretofore tax exempt activities into the tax net. Other topics on the agenda include BEPS and Aircraft Leasing; Tax Classification of Foreign Entities; VAT in the area of digitalisation, the Land Value Sharing legislative proposals; Ireland's corporate tax take and from a recent ruling by the TAC, the importance of keeping proper books.
Maples' Head of Tax Andrew Quinn writes in the May edition of the Irish Tax Monitor, ahead of the release of details of the new Pillar II 'Top up Tax' ('QDTT'), that Ireland could levy the top-up tax on "under-taxed" entities within the scope of the Directive and not exempted or under a safe harbour in the Directive. "That could mean that Ireland could levy tax in certain limited cases on entities that to date have generally been treated as tax exempt in Ireland under Irish tax legislation, such as an Irish regulated fund", he says.
Writing on the proposed Land Value Sharing Bill, in the May edition of the Irish Tax Monitor, Dominic O'Shaughnessy, Tax Director, Corporate & International Tax, Deloitte says the proposed changes add to the air of uncertainty in the market with the inclusion of existing zoned land likely to be the most contentious change. "While, in principle, there are arguments for a form of LVS contribution, applying LVS to land that is already zoned would not seem equitable, as such lands would have been purchased at a price that did not take into account the impact of the LVS contribution", he says. Read more
here.
Angela Fleming, BDO's head of FS Tax, reviews the new Guidance from Irish Revenue on the classification of foreign entities for Irish tax purposes, and notes their decision not to adopt the approach of HMRC in the UK of providing a list of examples of foreign entities and their classifications. The proposed Irish approach will be to look at each foreign entity on its own merits based on established principles set out in case law, and, she notes, potential use of the Irish RTS (Revenue Technical Service) for clarifications.