"From Finance to Pharma, Why Companies Small & Large Host in Ireland"
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Presentation from the Host in Ireland event on November 10, 2016.
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"From Finance to Pharma, Why Companies Small & Large Host in Ireland"
- 3. #HII2015
- 7. Why = “Data” How = “Centre” #Hos%nIreland
- 19. Financial Times 2012-2015 Matheson is ranked in the FT’s top 10 European law firms 2015. Matheson has also been commended by the FT for corporate law, finance law, dispute resolution and corporate strategy. Irish Transfer Pricing Firm of the Year 2015 International Tax Review European Law Firm of the Year 2015 Hedge Fund Journal Law Firm of the Year 2014 Irish Pensions Awards Policy to the Max! The Schrems decision in context Andreas Carney, Senior Associate IT & Commercial Contracts Department
- 20. Government Policy • Ac%on Plan for Jobs 2013 and 2015 • Leading country for Big Data and data analy%cs • Compe%%ve ecosystem for Big Data
- 22. Safe Harbour - a liPle history • 2000 - European Commission / US Dept. of Commerce • Set down principles for processing data • Sign-up and self-cer%fy compliance • 2010 – German DPAs ques%on adequacy
- 23. Snowdon Revela%ons • 2013 - Commission - Safe Harbour may not be safe aYer all • 2014 – Parliament – calls for immediate suspension • 2015 – German DPAs – does not protect fundamental rights • No pressure then….
- 24. The Court’s Decision • Basis of the decision • Considerable unease about indiscriminate surveillance • PermiPed deroga%on from Safe Harbour principles • Meet na%onal security or law enforcement obliga%ons • Agencies outside the regula%on of Safe Harbour
- 25. Policy? • Was the Court’s decision reflec%ve of a wider policy? • Number of op%ons to legi%mise transfers, but… • If laws are not equivalent to those in Europe? • Are all transfers to a jurisdic%on at risk?
- 26. Housing Data in Europe • Mul%na%onals choosing to house their data here • Op%ng for regula%on here • See it happening more and more
- 30. Financial Times 2012-2015 Matheson is ranked in the FT’s top 10 European law firms 2015. Matheson has also been commended by the FT for corporate law, finance law, dispute resolution and corporate strategy. Irish Transfer Pricing Firm of the Year 2015 International Tax Review European Law Firm of the Year 2015 Hedge Fund Journal Law Firm of the Year 2014 Irish Pensions Awards The International Tax Landscape Joe Duffy, 10 November 2015
- 31. Base Erosion Profit Shifting – BEPS 2008 - 2012 • Financial Crisis • G20 2013 • OECD Action Plan 2014 • OECD Phase 1 Reports 2015 • OECD Phase 2 Reports 2016 • Implem- entation • Review
- 32. OECD Reports Coherence Hybrid Mismatch Arrangements (2) Harmful Tax Practices (5) Interest Deductions (4) CFC Rules (3) Substance Preventing Tax Treaty Abuse (6) Avoidance of PE Status (7) TP Aspects of Intangibles (8) TP/Risk and Capital (9) TP/High Risk Transactions (10) Transparency Methodologies and Data Analysis (11) Disclosure Rules (12) TP Documentation (13) Dispute Resolution (14) Digital Economy (1) Multilateral Instrument (15)
- 33. The Digital Economy The Digital Economy Not separate Allocating profit Watch this space Taxable presence
- 34. Ireland’s Corporate Tax Strategy
- 35. Ireland’s Corporate Tax Strategy Rate Regime Reputation “Ireland’s corporate tax strategy has three key elements: rate, regime and reputation. The tax rate is settled policy.” “I want Ireland to play fair…and to play to win…I will continue to examine ways to ensure our corporate tax regime remains competitive.”
- 36. Ireland’s Corporation Tax Strategy 12.5% tax rate Residency rules Onshoring IP SARP Knowledge Development Box Aligning Profit with Value Creation Real Substance in Ireland
- 37. Knowledge Development Box Qualifying Expenditure Overall income from IP Asset Overall Expenditure = Qualifying Expenditure + Acquisition Costs + Group Outsourced Costs 30% Uplift Income receiving tax benefits @ X = + 6.25%
- 44. 44 | Proprietary and Confidential Zayo Global Network 17,400 buildings 6,700,000 fiber miles 84,000 route miles 320 markets 80 average fiber count Metro Fiber Market Longhaul / Regional Fiber Legend
- 45. 45 | Proprietary and Confidential Zayo European Network
- 46. 46 | Proprietary and Confidential Focused on a full product suite Product Offering % Revenue Dark Fiber Leased raw fiber 32% Mobile Infrastructure Tower/small cell backhaul 7% Interconnect-Oriented Colo Space, power & interconnects 8% Subtotal 47%
- 47. 47 | Proprietary and Confidential Cable system overview Sirius NorthHibernia Atlantic Lanis 2 BT-Manx Lanis 1 Hibernia Atlantic ESAT 2 Sirius South Eirgrid CeltixConnect EBFL Hibernia Atlantic ESAT 1 SOLAS TGN and Apollo
- 48. 48 | Proprietary and Confidential Irish Connectivity Our combined network topology brings key differentiators in this space: • Sea crossing diversity • Backhaul diversity to major UK cities, including Gold: Eirgrid Green: EBFL Red: FibreSpeed Blue: Zayo
- 49. 49 | Proprietary and Confidential Key players in the Irish market Dublin one of the leading markets in Europe. Local metro access : • Partnership with ESBT • Access through T50 • Bespoke build
- 52. Q4 Events
- 54. #Hos%nIreland