Three Chartered Accountants weigh in on how the outcome of the US presidential election might impact the future of foreign direct investment in Ireland, exploring potential economic shifts and changes to the corporate tax regime Paraic Burke Head of Tax PwC Ireland Despite international uncertainties, Ireland’s economy continues to be one of the best-performing in Europe.  Employment remains at a historic high, our fiscal position is strong and inflation is easing. Global companies here continue to see the opportunities Ireland presents as a gateway to Europe and further afield, with a highly skilled workforce in a stable business environment.  The impact of the US election on Ireland’s FDI from a tax and business perspective is two-fold:   1. The US election should determine how the US responds to the stalled element of global tax reforms led by the Organisation for Economic Cooperation and Development. While Ireland and EU member states have enshrined Base Erosion and Profit Shifting Pillar Two into their domestic law, the US has not.  Depending on a complex series of political factors, we could see increasing tensions between the US and Europe, which could have big implications for Ireland. Under a clause in the Pillar Two agreement called the undertaxed profits rule (UTPR) – a way of ensuring that multinational companies pay the globally agreed 15 percent corporate tax rate on their profits – the Irish Government, like others across the EU, could find itself having to tax US profits.  This would not sit well with the US Government. If it is not dealt with, it could have serious trade implications for multinational companies exporting from Ireland. The outcome of the election will very likely have a significant impact on the US approach in this context. 2. This US election will also determine who deals with the potential expiration in 2025 of the individual tax rate cuts introduced by Donald Trump in 2017.  As part of the overall strategy in this context, Democratic candidate Kamala Harris has outlined a plan to raise the US corporation tax rate to 28 percent (currently at 21 percent), but this is likely to be politically impossible.  On the other hand, if elected as US President for a second term, Trump has mentioned a reduction in the US corporate tax rate to 15 percent – although, again, this is likely to be impossible given the overall US fiscal position.  In addition, Trump has regularly stated that he may adopt a policy of applying tariffs on all US imports, a move that could greatly disrupt global trade, including Irish exports.  Cormac Kelleher International Tax Partner Forvis Mazars The upcoming presidential election in the US, due to take place in November, is delaying US companies in making their foreign direct investment (FDI) decisions.  Uncertainty over upcoming trade policy is causing new and existing US businesses to pause decision-making. However, it has not stopped firms from exploring and readying themselves for investment decisions in 2025. If the US introduces or strengthens existing tax repatriation programs post-election, as seen in the Tax Cuts and Jobs Act of 2017, it could incentivise US companies to bring profits and operations back home, possibly reducing FDI in Ireland.  However, given Ireland’s low corporate tax rate (12.5%) and status as a key EU hub for the technology and pharmaceutical sectors, US firms might still find Ireland an attractive location for their European operations. It will be interesting to watch the level of US engagement with the OECD’s BEPS 2.0 tax proposals.  This year has delivered probably the most significant level of tax reform practitioners are likely to witness.  The effective 15 percent rate has caused multinational groups to grapple with a plethora of complex and challenging legislation. Despite initial positive soundings from the US Treasury, achieving sufficient political appetite for the introduction of BEPS 2.0 (Pillar Two) has proved elusive.  The rules, however, will result in US-headquartered groups being affected by the global minimum tax rules from 2026 onwards.  If Pillar Two plans continue to have momentum, commentators will watch with interest to see how the US will react and whether retaliatory measures will be introduced. While tax policy is an important feature of Ireland’s FDI offering, there are many other features that are equally attractive and important to organisations when seeking to establish an international presence.  This is particularly important for firms establishing their first presence outside the US.  Ireland will continue to be an important cog in the global international tax expansion plans of US-based multinational groups. Fundamentals – including making Ireland an attractive location for people to relocate to – will play a greater role in years to come. Catherine Drysdale Consultant Barden Ireland's job market is highly interconnected with global trends and events. There are a number of key factors impacting the employment industry in Ireland at present, including the upcoming US election and potential impact on FDI, geopolitical conflicts, climate initiatives, uncertainty regarding policy and regulatory changes and interest rates and inflationary impacts. How these directly impact talent looking for opportunities within US companies headquartered in Ireland will be sector dependent. Certain sectors, for example, will be impacted more significantly by policy and regulatory changes including technology, pharmaceutical and financial services industries.   The challenges for acquiring talent may include: Changes in visa policies and global mobility restrictions; Cautious spending that could result in longer, more complex hiring processes coupled with the risk that companies will prioritise hiring local talent in the US due to shifting labour policies or cost-saving measures; A shift to contract opportunities, a trend we have already witnessed, reflecting employers’ desire for flexibility and a cautious approach to permanent hires; and Increased competition among jobseekers for a reduced number of opportunities, potentially leading to longer lead time to secure new roles. The stance companies are taking on hybrid and remote working arrangements remains in flux. We saw the recent announcement from Amazon CEO Andy Jassy regarding a mandatory full-time return to office. Whether others follow suit remains to be seen.  Organisations could adopt permanent remote working policies. While this may open up opportunities for a broader talent pool and flexible working arrangements, professionals in the Irish market would likely face increased competition from the global talent pool, potentially leading to downward pressure on salaries as companies seek cost-effective labour. With potential changes in the US economic environment post-election, given their established presence in Ireland, US companies with operations here may need to adjust their salary structures to remain competitive in attracting top talent, particularly if remote work opportunities expand.  A focus on enhancing their existing localised talent acquisition strategies, coupled with a strong emphasis on employer branding to showcase corporate culture and values, will help to make positions more attractive in a competitive market.  

Minster for Finance, Jack Chambers, last week published the report of the independent examination of the Standard Fund Threshold (SFT). Following this review, the Government will implement phased increases in the SFT of €200,000 per year beginning in 2026 until 2029; after which the level of SFT will move with the applicable level of wage growth.    The SFT is the limit on the total capital value of an individual’s pension pot before unfavourable tax consequences are realised and has remained at €2 million for the past 10 years.   The Institute, under the auspices of the CCAB-I, responded to the public consultation on the SFT regime in December 2023 and recommended that the SFT should be increased in line with inflation as well as harmonising the treatment of public and private sector pensions when the SFT is breached.   The Minister also confirmed that there would be no change to the rate of chargeable excess tax (CET), currently 40 percent, but that this would be reviewed in 2030.  In relation to lump sums, the threshold for the higher rate of taxation to apply to a pension lump sum will be limited to €500,000 rather than a proportion of the SFT and this change will be introduced in Budget 2025.   Read the Minister's statement announcing the changes.  

As anticipation for an early general election continues to grow, the Institute’s public policy team has made submissions to all of the main political parties setting out the key policy priorities we would like to see featured in any future Programme for Government. Read our manifesto. Supporting small businesses While the Government has acknowledged the financial pressures SMEs are under, many businesses remain constrained by rising labour costs. In a recent survey of our members, 90 percent of respondents identified labour costs as being the single biggest operating cost facing their business today with over 90 percent saying that these have increased over the past year. With this in mind, we are calling for the next Government to: 1. Reduce Employers’ PRSI on minimum wage workers by 1.5 percent to mitigate the cost of auto-enrolment for employers Currently employers’ PRSI is paid at a rate of 8.8 percent (8.9 percent from October 2024) and a reduction by 1.5 percent would cost the Exchequer an estimated €63 million in a full year. This proposal would compensate employers who will have to introduce pensions auto-enrolment during 2025 at an initial cost of 1.5 percent. The cohort most impacted by the new pensions scheme will be the estimated 164,000 minimum wage workers. 2. Think small first when it comes to introducing new legislation and regulations SMEs have also had to deal with the introduction of an unprecedented number of new legislative requirements over the past 2 years, adding to their cost and administrative burden.  One example is the introduction of enhanced reporting for employers meaning that employers have to report in real-time details of tax-free travel and subsistence and other benefits paid to employees.  Government needs to be cognisant of these challenges when implementing new regulations and have regard to the timing and suitability of same. It is important that small companies do not face any unnecessary or disproportionate regulatory obstacles to start up, establish and grow.  This can be achieved by: Strictly applying the ‘enhanced SME test’ across all government departments when introducing new legislation that will ultimately affect the bottom lines of SMEs. Staggering the roll out of new workplace legislation in a timely manner so as not to overburden employers with additional new costs all at the same time. Facilitating consultation and dialogue with SMEs and other impacted stakeholder groups before introducing new legislation or policy that affects small businesses. Reducing the frequency of reporting the payment of travel and subsistence and other benefits to a monthly or annual basis. 3. Simplify the tax regime for SMEs to encourage enterprise and innovation It is acknowledged that businesses face a complex challenge in accessing tax reliefs and schemes and the Government has shown a desire for all businesses, especially SMEs, to know what they are entitled to claim and can access all appropriate schemes and reliefs.   However, there are several areas where improvements must be made including: (i) Making share-remuneration more attractive by: Maintaining the Employers’ PRSI exemption, which offsets some of the cost of establishing share schemes. Deferring all tax charges for the employee until a sale or liquidity event occurs and allowing CGT treatment on a redemption of employee-owned shares. Enhancing the Key Employee Engagement Programme (KEEP) scheme by relaxing some of the onerous conditions for establishment which drives set-up costs. (ii) Encouraging SMEs to claim the R&D tax credit Larger organisations represent a larger proportion of the amount of R&D tax credit claims in a year. Smaller organisations are disincentivised from claiming an otherwise-available R&D tax credit on the basis of a lack of certainty, fundamental tax risk, and burdensome scrutiny of claims. This can be achieved by: Offering an enhanced rate for small and micro companies of 50 percent. Simplifying the documentation and qualification requirements for SMEs. Introducing a Revenue pre-clearance system for first time claimants. Improving Revenue guidance targeted at SMEs and including a list of common pitfalls encountered by claimants. (iii) Reduce Capital Gains Tax from 33 percent to 25 percent Investment is critical in enabling start-ups to thrive and SMEs to grow and expand.  A lower rate of CGT has been shown to encourage innovation and risk taking. It encourages the sale and purchase of assets, which drives investment activity. This would improve returns for entrepreneurs and in turn the Exchequer.  Improving childcare capacity and affordability for working parents Childcare provision is part of the critical infrastructure necessary for a functioning economy. Access to affordable and good-quality childcare can play a key role in driving more sustainable and inclusive economic growth. In a survey of our members published earlier this year, 97 percent of respondents surveyed said that they had considered adjusting their working patterns as a result of not being able to find a childcare place while almost half of respondents signalled that they have had to reduce their working hours as a result of this. From a cost perspective, one third of members currently pay up to €1,000 a month per child on childcare with one third paying between €1,000 and €2,000 per child per month. This is not a sustainable situation. To address these issues, we are calling on the next Government to: 1. Commit to a whole-of-government strategy which recognises childcare as part of the critical infrastructure necessary for the functioning of the economy. This strategy should: Focus on encouraging the availability of flexible or part-time childcare places to reflect current work patterns. Targeted funding could be directed at facilities to offer more flexible offerings. Ensure adequate capacity in the sector by officially analysing and documenting childcare needs in local areas on a regular basis.  Expand the work of the Access and Inclusion Model (AIM) programme which caters for children with a disability by creating a more inclusive environment in pre-schools through universal and targeted supports. 2. Ensure funding of the existing system reflects the true cost of service provision and encourages growth in the sector. This can be achieved by: Regularly reviewing Core Funding to ensure that the model is suitable for the sector and enables providers to be sustainable, profitable and retain an ability to invest in their own services. Supporting an integrated system of full time and after-school care with both types of care adequately funded. Reflecting the additional cost burden placed on providers by the administrative requirements of Core Funding, the administration of the National Childcare Subsidies as well as the enhanced regulation experienced by childcare providers (and SMEs generally) by the introduction of new labour laws including pensions auto-enrolment, which is expected in 2025.   3. Enhance awareness of support subsidies available to parents under the National Childcare Scheme. This can be achieved by: Ensuring that maternity hospital and Public Health Nurses to provide information on the supports available to new parents in the early years. Requiring childcare providers to highlight available supports to parents as part of the application process to register their child with the childcare facility. Translating the NCS portal into other languages as language barriers have been reported as being a barrier to claiming the subsidy. As part of our pre-election campaign to promote the above advocacy agenda, in recent weeks representatives from the Institute have met with Minister for Enterprise, Trade and Employment Peter Burke and Minister for Finance Jack Chambers. In addition, we have engaged with senior officials at the Department of Children, Equality, Disability, Integration and Youth and have arranged forthcoming meetings with spokespeople from all of the main opposition parties. As we approach the next general election, the Institute’s public policy team will continue to advocate for our members interests across the political spectrum. Should you have any questions on our campaign or wish to bring a specific issue to our attention, please contact the public policy team at publicpolicy@charteredaccountants.ie  

As anticipation for an early general election continues to grow, the Institute’s public policy team has made submissions to all of the main political parties setting out the key policy priorities we would like to see featured in any future Programme for Government. Supporting small businesses While the Government has acknowledged the financial pressures SMEs are under, many businesses remain constrained by rising labour costs. In a recent survey of our members, 90 percent of respondents identified labour costs as being the single biggest operating cost facing their business today with over 90 percent saying that these have increased over the past year. With this in mind, we are calling for the next Government to: 1. Reduce Employers’ PRSI on minimum wage workers by 1.5 percent to mitigate the cost of auto-enrolment for employers Currently employers’ PRSI is paid at a rate of 8.8 percent (8.9 percent from October 2024) and a reduction by 1.5 percent would cost the Exchequer an estimated €63 million in a full year. This proposal would compensate employers who will have to introduce pensions auto-enrolment during 2025 at an initial cost of 1.5 percent. The cohort most impacted by the new pensions scheme will be the estimated 164,000 minimum wage workers. 2. Think small first when it comes to introducing new legislation and regulations SMEs have also had to deal with the introduction of an unprecedented number of new legislative requirements over the past 2 years, adding to their cost and administrative burden.  One example is the introduction of enhanced reporting for employers meaning that employers have to report in real-time details of tax-free travel and subsistence and other benefits paid to employees.  Government needs to be cognisant of these challenges when implementing new regulations and have regard to the timing and suitability of same. It is important that small companies do not face any unnecessary or disproportionate regulatory obstacles to start up, establish and grow.  This can be achieved by: Strictly applying the ‘enhanced SME test’ across all government departments when introducing new legislation that will ultimately affect the bottom lines of SMEs. Staggering the roll out of new workplace legislation in a timely manner so as not to overburden employers with additional new costs all at the same time. Facilitating consultation and dialogue with SMEs and other impacted stakeholder groups before introducing new legislation or policy that affects small businesses. Reducing the frequency of reporting the payment of travel and subsistence and other benefits to a monthly or annual basis. 3. Simplify the tax regime for SMEs to encourage enterprise and innovation It is acknowledged that businesses face a complex challenge in accessing tax reliefs and schemes and the Government has shown a desire for all businesses, especially SMEs, to know what they are entitled to claim and can access all appropriate schemes and reliefs.   However, there are several areas where improvements must be made including: (i) Making share-remuneration more attractive by: Maintaining the Employers’ PRSI exemption, which offsets some of the cost of establishing share schemes. Deferring all tax charges for the employee until a sale or liquidity event occurs and allowing CGT treatment on a redemption of employee-owned shares. Enhancing the Key Employee Engagement Programme (KEEP) scheme by relaxing some of the onerous conditions for establishment which drives set-up costs. (ii) Encouraging SMEs to claim the R&D tax credit Larger organisations represent a larger proportion of the amount of R&D tax credit claims in a year. Smaller organisations are disincentivised from claiming an otherwise-available R&D tax credit on the basis of a lack of certainty, fundamental tax risk, and burdensome scrutiny of claims. This can be achieved by: Offering an enhanced rate for small and micro companies of 50 percent. Simplifying the documentation and qualification requirements for SMEs. Introducing a Revenue pre-clearance system for first time claimants. Improving Revenue guidance targeted at SMEs and including a list of common pitfalls encountered by claimants. (iii) Reduce Capital Gains Tax from 33 percent to 25 percent Investment is critical in enabling start-ups to thrive and SMEs to grow and expand.  A lower rate of CGT has been shown to encourage innovation and risk taking. It encourages the sale and purchase of assets, which drives investment activity. This would improve returns for entrepreneurs and in turn the Exchequer.  Improving childcare capacity and affordability for working parents Childcare provision is part of the critical infrastructure necessary for a functioning economy. Access to affordable and good-quality childcare can play a key role in driving more sustainable and inclusive economic growth. In a survey of our members published earlier this year, 97 percent of respondents surveyed said that they had considered adjusting their working patterns as a result of not being able to find a childcare place while almost half of respondents signalled that they have had to reduce their working hours as a result of this. From a cost perspective, one third of members currently pay up to €1,000 a month per child on childcare with one third paying between €1,000 and €2,000 per child per month. This is not a sustainable situation. To address these issues, we are calling on the next Government to: 1. Commit to a whole-of-government strategy which recognises childcare as part of the critical infrastructure necessary for the functioning of the economy. This strategy should: Focus on encouraging the availability of flexible or part-time childcare places to reflect current work patterns. Targeted funding could be directed at facilities to offer more flexible offerings. Ensure adequate capacity in the sector by officially analysing and documenting childcare needs in local areas on a regular basis.  Expand the work of the Access and Inclusion Model (AIM) programme which caters for children with a disability by creating a more inclusive environment in pre-schools through universal and targeted supports. 2. Ensure funding of the existing system reflects the true cost of service provision and encourages growth in the sector. This can be achieved by: Regularly reviewing Core Funding to ensure that the model is suitable for the sector and enables providers to be sustainable, profitable and retain an ability to invest in their own services. Supporting an integrated system of full time and after-school care with both types of care adequately funded. Reflecting the additional cost burden placed on providers by the administrative requirements of Core Funding, the administration of the National Childcare Subsidies as well as the enhanced regulation experienced by childcare providers (and SMEs generally) by the introduction of new labour laws including pensions auto-enrolment, which is expected in 2025.   3. Enhance awareness of support subsidies available to parents under the National Childcare Scheme. This can be achieved by: Ensuring that maternity hospital and Public Health Nurses to provide information on the supports available to new parents in the early years. Requiring childcare providers to highlight available supports to parents as part of the application process to register their child with the childcare facility. Translating the NCS portal into other languages as language barriers have been reported as being a barrier to claiming the subsidy. As part of our pre-election campaign to promote the above advocacy agenda, in recent weeks representatives from the Institute have met with Minister for Enterprise, Trade and Employment Peter Burke and Minister for Finance Jack Chambers. In addition, we have engaged with senior officials at the Department of Children, Equality, Disability, Integration and Youth and have arranged forthcoming meetings with spokespeople from all of the main opposition parties. As we approach the next general election, the Institute’s public policy team will continue to advocate for our members interests across the political spectrum. Should you have any questions on our campaign or wish to bring a specific issue to our attention, please contact the public policy team at publicpolicy@charteredaccountants.ie  

Last week, a delegation from the Institute, under the auspices of the CCAB-I, met the Minister for Finance, Jack Chambers TD to discuss this year’s Pre-Budget 2025 submission. The Minister was joined by several key senior officials from his department who facilitated an engaging and thorough discussion on a number of our proposals. We raised our concerns over the increased cost of doing business for SMEs in particular, the potential to reduce Employers' PRSI and reducing the headline rate of CGT from 33 percent to 25 percent. We also raised concerns about capacity and adequate childcare, and how the lack of affordable childcare is impacting workers. In addition, we reiterated many of our recommendations for enhancing share-based remuneration, particularly for SMEs, including recommending a deferral of the upfront tax charge on unapproved share options and a safe harbour for valuations for private companies instituting share schemes. We discussed the impact of the new Enhanced Reporting Requirements on businesses and the ongoing question about the need for businesses to report in real-time or, or before in-scope payments are made to employees. The requirement to file on a real-time basis does not seem to add any integrity to the information reported to Revenue but has caused significant problems for affected businesses and workers. We also suggested that two-gift limit applying to the small benefit exemption should be removed with the only limit being by reference to the total value of non-cash benefits made in a year, i.e. a taxpayer should be entitled to receive any number of non-cash benefits up to €1,000 as long as those benefits are not part of a salary sacrifice arrangement. The Institute is grateful to Minister Chambers for taking time to meet with us and consider our proposals. We wish the Minister every success in his new role and look forward to continued engagement with him and his office.

  A Pride festival in the UK has gained recognition for combining both inclusivity and sustainability in its operations. Worthing Pride, an annual celebration in the UK coastal town of Worthing, has implemented a waste management plan encouraging attendees to participate in green practices and including efforts to reduce single-use plastics, in order to reduce its environmental impact. It also offers a platform for local businesses and small business owners and artisans to showcase their products, both supporting local services/products and reducing the event’s carbon footprint. It is also promoting eco-friendly vendors among other sustainability initiatives. The event, which takes place in July, supports local environmental charities, with a direct focus on clean energy projects that benefit underrepresented communities or support LGBTQ+ environmental activists.