WENTWORTH provides a wide range of corporate tax planning and consultancy services to our corporate clients. We work closely with our clients and gain an understanding of their long term goals which allows us to assist them to plan their affairs in a manner which is both tax efficient and commercial.
Examples of personal tax planning and consultancy services offered by WENTWORTH are as follows:
Corporate Restructuring & Reorganisation
SMEs and corporates can require a corporate restructure or reorganisation due to internal or external factors, including:
- Requirement to protect existing wealth
- Condition of finance provider
- Improve corporate governance
- Partition of the company between existing shareholders
- Sale or merger
- Cash extraction
- Share buy back
A transfer of a business or shares can generate a number of tax implications such as capital gains tax, stamp duty, corporation tax, VAT and income tax, together with company law issues.
To ensure that any restructuring or reorganisation is executed in a manner that is tax efficient and commercial, it is essential that tax planning is undertaken and professional advice is sought.
WENTWORTH professionals have extensive experience in this area and can assist you with all aspects of your restructure.
Merger & Acquisitions
The merger with, or the acquisition of, a business will give rise to many corporate finance and taxation related issues. When considering any M&A transactions, it is important to consider the taxation implications under the relevant tax heads including; corporation tax, capital gains tax, stamp duty, VAT, withholding taxes and PAYE/PRSI.
WENTWORTH professionals have extensive experience in this area and can assist you with all aspects associated with M&A transactions.
Our tax professionals will work closely with our corporate finance advisers to provide you with a complete financial solution to the following issues:
- Pre-acquisition restructuring
- Taxation due diligence
- Advice on tax warranties
- Advise on tax efficient exit packages for executives or staff of the target business
- Tax efficient payment structure for acquisitions
Management Buy Out
When considering a MBO, it is important to consider the taxation implications under the relevant tax heads including corporation tax, capital gains tax, stamp duty, VAT, withholding taxes and PAYE/PRSI.
Our tax professionals work closely with our corporate finance advisers to provide you with a complete financial solution to this complex transaction.
At WENTWORTH we have considerable experience in advising on MBOs in areas such as:
- Taxation due diligence
- Tax warranties
- Tax efficient exit packages for executives or staff of the target business
- Tax efficient payment structure
Share Buy Back
In many SMEs, there is a limited or no market for the sale of company shares. Buy back is a mechanism whereby, subject to certain conditions, the company can buy back its own shares from a shareholder by using its retained reserves. This is a mechanism that can be employed as part of a cash extraction scheme or a retirement/succession strategy.
When carrying out a share buy back there are both taxation and company law implications that need to be considered. WENTWORTH has extensive experience in this area and can assist you with all aspects associated with a share buy back.
Cash Extraction
Stakeholders commonly seek to extract cash from a business. This may be in the form of a regular payment, or larger one off payments. The extraction of cash from a company can give rise to taxation and company law issues.
WENTWORTH specialists will guide you on the most tax efficient means of extracting cash and, advise you on structures that are compliant with company law requirements.
The cash extraction methods employed can include salary, dividends, share buy backs, sale of assets, pension depending on each case and the personal tax circumstances
Intellectual property
Ireland offers many advantages to companies seeking to establish a base here to exploit intellectual property. The standard rate of corporation tax on trading profits arising in Ireland is 12.5%. In addition capital allowances can be claimed on capital expenditure incurred by companies, on the provision of certain “specified intangible assets.”
The tax write-off is granted as a capital allowance for capital expenditure incurred on the acquisition of qualifying assets (including the licence to use ;)
- Patents and registered designs
- Trademarks, brands, brand names
- Domain names and services marks
- Copyright or related rights
- Know-how, generally related to manufacturing or processing, industrial, commercial or scientific experience whether protected or not
- Goodwill to the extent that it is directly attributable to specified intangible assets
- Computer software or a right to deal in or use such software
- Applications for grant or registration of patents, trademarks, copyrights etc.
A company can elect to take the write off against its taxable income over a 15 year period. A clawback of the capital allowances claimed arises if the intellectual property is sold within five years of its acquisition (or 10 years in respect of capital expenditure incurred before 13 February 2013.)
The capital allowances that are available can only be offset against income generated from exploiting intangible assets or, as a result of the sale of goods or services that derive the greater part of their value from the intangible assets (referred to as a “relevant trade.”)
The aggregate amounts of allowances that can be claimed are capped at 80% of profits from the relevant trade in a given accounting period. Unused allowances can be carried forward and treated as an allowance in succeeding accounting periods.
The allowances can reduce the overall effective rate of corporation tax on intellectual property and, provide a valuable incentive to companies looking at locating in Ireland to exploit intellectual property.
Our services include:
- IP corporate structures
- Relocating IP to Ireland
- Maximisation of returns from the exploitation of IP
Other relevant services;