Irish revenue commissioners will no longer require outside investors to complete a non-resident tax declaration as part of the fund subscription process, easing administrative costs for private equity funds domiciled in the country.
The change is the result of a new provision in the Irish Finance Act 2010, which says that in lieu of the declaration, the fund must put in place “equivalent measures” which satisfy the revenue commissioners.
Dublin: More attractive to foreign |
Prior to the change, outside investors who failed to declare themselves a non-resident were deemed to be Irish by default, meaning they were liable to pay Irish tax on their income and gains.
With investors in Irish funds being overwhelmingly non-Irish residents, the non-resident tax declaration was considered an unnecessary administrative burden, according to a client note issued by international law firm Dechert.