•  
• Tweet
•  
•        Print
•  
•         Track Keywords
•  
• 

By: Nicolas Kokkinos, David Layden, Stephen Nolan, Declan O'Sullivan

On October 10, 2024, the Irish government published the Finance Bill 2024, which proposes to introduce two important amendments to Irish tax legislation that, when enacted, will positively impact Ireland's private funds offering. The proposed amendments are:

the extension of the value added tax ("VAT") exemption for fund management supplies to all relevant Irish 1907 limited partnerships ("1907 LPs"); and

the introduction of a foreign dividend participation exemption.

These two amendments will enhance Ireland's appeal as a jurisdiction for private funds and in particular for private equity funds. Below is a brief overview of these two changes and the implications for private funds.

1. Extension of the VAT exemption for Fund Management Supplies to 1907 LPs

While regulated Irish UCITS and Alternative Investment Funds ("AIFs") such as ICAVs, Irish investment limited partnerships ("ILPs"), common contractual funds and unit trusts are eligible for an exemption from VAT in respect of management services, unregulated structures such as 1907 LPs have not been eligible other than in certain circumstances. As a result, supplies of investment management to 1907 LPs created additional tax leakage because such supplies were standard rated for Irish VAT purposes, and this VAT cost could not be recovered by the 1907 LPs.

The Bill proposes......................

To view our full article Click here