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.  

IDA Chair Feargal O’Rourke, FCA, talks to Accountancy Ireland about the inward investment agency’s plans and priorities at a “critical juncture” in Ireland’s FDI journey Feargal O’Rourke, FCA, assumed the role of Chair of IDA Ireland in January 2024 at a significant time for the inward investment agency, which celebrates its 75th anniversary this year – and, he says, a “critical juncture” in Ireland’s foreign direct investment (FDI) journey. O’Rourke joined the board of IDA Ireland after stepping down as Managing Partner of PwC Ireland in October 2023 following a storied 37-year career with the firm. In his new role, working alongside IDA Ireland Chief Executive Michael Lohan, time is, he says, “of the essence.” “The one thing I am always paranoid about is complacency, and I think you really do need to have a paranoia about that,” O’Rourke tells Accountancy Ireland.  “Right now, I think Ireland has ‘amber lights’ on infrastructure and we need to put the foot down. We need to invest in more housing. We need to invest in the grid. We need to invest in offshore energy.  “My biggest concern is speed. There are plans in place, but I constantly ask myself, ‘Are we moving fast enough? Can we move faster?’ “I think there is a broad consensus emerging that infrastructure is moving up our list of priorities.  “I take the view that capital spend on infrastructure is an investment. It is not an outflow of money. Deferring a project is a cost. It is not a saving because we will have to do it at some point, and it may cost more then.” New five-year strategy The single biggest task for IDA Ireland as an organisation currently is finalising a new five-year strategy, which will run from 2025 to 2029, O’Rourke says.  “We are doing this against the backdrop of significant geopolitical uncertainty. There is a more muted pace of growth in the global economy and more active industrial policy from some competitor nations,” he says. “There is also the challenge of climate change and the opportunity of the green transition, companies globally grappling with the next step on their diverse digitalisation journeys and, of course, the revolution that is taking place in artificial intelligence.” Ireland’s ability to continue competing in this fast-changing world will be dependent on having the right set of enabling conditions in place”, O’Rourke says.  “As we face challenges in terms of our national competitiveness relating to energy costs and renewable energy provision, housing, infrastructure and utilities, countries around the world are vying to win the race for the next generation of FDI growth. “The opportunity cost of not addressing these issues in a timely manner – particularly sustainable energy supply – risks being sizeable,” he warns. Storied career in practice A native of Athlone, O’Rourke studied commerce and accounting at University College Dublin and qualified as a Chartered Accountant with PwC in 1989. He is also an Associate of the Irish Tax Institute and current Chair of the Institute of International and European Affairs, the Irish-based international think tank. “My father left school at 16, so he always placed a big emphasis on education and business,” O’Rourke says. “He thought I should qualify as a Chartered Accountant and the ‘Chartered’ bit was very important to him, because he felt it had a cachet. That was back in the eighties, and I think the qualification still holds a distinction today. “I remember sitting my final accounting exams thinking, ‘I wonder what this bit of paper will do for my life?’ “There is no doubt that having the Chartered Accountant qualification contributed so much to me living out my professional dreams in the years that followed. The status it brought with it is hugely important and I think the standing of the qualification is as strong today as it was when I qualified.” O’Rourke joined PwC in Dublin in 1986 and remained with the firm for 37 years, holding the position of Managing Partner for the last eight. “I joined what was then Price Waterhouse on 8 October 1986, with the intention of qualifying as a Chartered Accountant and then returning home to Athlone,” he recalls. “Thirty-seven years later – to the day – I retired from PwC having had a wonderfully fulfilling career that was beyond any expectations I had when I joined.” His experience with the firm instilled in O’Rourke the importance of strategic planning for long term success – and it is a lesson he has brought with him to IDA Ireland. “You can’t just think about an organisation as it exists today, and the current generation. You must ask yourself, ‘when I’m 20 and 30 years gone, will I have seeded the fields to ensure it continues to succeed long into the future?’” With Central Statistics Office figures released earlier this year predicting Ireland’s population could grow to over seven million by 2057, O’Rourke’s vision for IDA Ireland is equally long term. “In my role with IDA Ireland today, I am thinking ahead to 25 or 30 years from now and asking, ‘what will Ireland look like then?’ “We have got to play our part in advising the system today if we want to have the right industrial base in the years ahead, not just to continue to attract FDI but also to support indigenous businesses and wider society at a time of ongoing population growth. “I feel a responsibility, as do many others in the system, to say, ‘okay, how does this organisation contribute to ensuring that we will have a successful society in which there are plenty of jobs for people? Do we have the infrastructure we need – both societal and industrial – whether that be in terms of housing, energy supply, water or transport?’  “These are as much societal issues as they are business issues and IDA Ireland will play its part. Building capacity is crucial. Ireland is facing infrastructural capacity issues, and they are a priority for IDA Ireland, particularly over the next five to six years.” FDI and global tax developments Having been appointed as a Tax Partner in 1996 and Head of PwC’s Tax Practice in 2011, O’Rourke spent a significant portion of his career working in Foreign Direct Investment (FDI).  “I worked extensively – but not exclusively – with household names from the West Coast of the US. I was privileged to work with many of the companies that now rank among the largest FDI employers in the country,” he says. “I still have the memo in which my then Partner Tadhg O’Donoghue said, ‘I’m going to ask you to focus on a particular area of tax – FDI.’ That one line in a memo almost 40 years ago completely determined my career and my life thereafter.” O’Rourke saw the evolution of Ireland’s FDI landscape firsthand over that span of time. “Tax became central to Ireland’s FDI proposition, delivering a major competitive advantage for us back in the eighties and nineties. It has really played a central role in how Ireland has positioned itself to attract FDI,” he says. As Head of PwC’s Tax Practice, O’Rourke also collaborated extensively with companies, officials, governmental bodies and the Organisation for Economic Cooperation and Development on the Base erosion and profit shifting (BEPS) initiative introduced in 2013 to curb tax avoidance among multinationals operating across different jurisdictions. “Successive Irish Governments over the past 15 years have really got it right on our FDI-related tax policy and we are now seeing the benefits of this in terms of our corporate tax take,” he says.  “That contribution to the State coffers is being used to build hospitals and schools, but other countries in the post-BEPS era are moving fast on their own FDI-friendly tax strategies, and I think we need to move quickly as well and make sure we continue to be agile and responsive, looking around the world and asking, ‘what lessons can we learn here from what others are doing?’” “A world-class organisation” Just over 10 months into his role with IDA Ireland, O’Rourke’s pride in the organisation is palpable. “In sporting terms, IDA Ireland is like Limerick in hurling or Manchester City in football,” O’Rourke says. “We have a fantastic record of success, but once the season is over, we must do it all again. We can survive a year where we are not top of the pile, but we can’t afford to enter a period where we are living off past glories. “You wouldn’t say to the Limerick hurling team, ‘you need to ease off the training for a few years and let everyone else catch up,’ nor would you say to Manchester City, ‘you shouldn’t buy any good players for now.’ “I don’t think IDA Ireland as an organisation should ever say, ‘we are doing really well, we could pull back a bit’. Life doesn’t work like that. Michael Lohan, our Chief Executive, often says, ‘when you turn off the tap, there is no guarantee that, when you turn it back on again, water will come out.’” As it stands, O’Rourke sees IDA Ireland as a “world-class organisation.” “This is not just my own view,” he says. “Over the course of my 37 years in professional services, I was repeatedly told this by clients who had experience of being ‘courted’ by a variety of inward investment agencies from around the world. “Today, our IDA Ireland clients tell me time and again, ‘we feel welcome in Ireland; we feel supported’.” These IDA Ireland client companies employ 300,583 people directly, accounting for 11 percent of total employment in Ireland currently. They spend a combined €35.8 billion annually on payroll and Irish-sourced goods and services, and €15.5 billion in capital expenditure. In total, 248 investments were approved by IDA Ireland in 2023 and a further 131 in the first six months of this year, with the potential to create some 27,000 jobs. “While I expect the pipeline of projects to continue to be strong as we move through 2024, the challenges we face to stay at the forefront of attractive locations to invest in are significant,” O’Rourke says. “If we stand back, there is no doubt that FDI flows have slowed a bit compared to, say, four or five years ago.  “This is, in part, because we have probably already seen the high watermark in globalisation. In retrospect, I think that occurred somewhere towards the end of the last decade.  “The good news for Ireland is that we are continuing to win FDI projects of substance and the 300,000 FDI direct employment figure is a new plateau for us.  “For many years, the benchmark for direct employment was 200,000. Now, our focus is on keeping that figure above 300,000 as we look to build on the next FDI cycle.” Emerging opportunities As IDA Ireland looks to future FDI growth, its focus will be centred on emerging opportunities in the ongoing green and digital transitions reshaping the global economy, O’Rourke says. “We recognise the need to help the Irish operations of global firms transform to thrive in a world that is changing fast.  “We actively partner with client companies on investments in talent development, digitalisation, research and development, innovation and sustainability, including decarbonisation,” he says. “When I was Managing Partner at PwC and we were at our most profitable and successful, we decided we needed to invest heavily in digitisation.  “It wasn’t just an investment in technology, it was an investment in our culture. Even though there were no clouds on the horizon, we could see that, if we stayed still, we might have another few great years – but, really, we needed to invest in the technology to continue growing beyond that. “Our focus now at IDA Ireland is on helping our clients to invest in the areas they need to focus on to do the same – to prepare to continue succeeding in the future. This means supporting them on investment in digitalisation and sustainability.” Collectively, IDA Ireland client companies spend over €7 billion on in-house research, development and innovation (RD&I) annually.  IDA Ireland approved 25 sustainability projects last year, focused on carbon abatement and building Ireland’s green economy.  New RD&I projects won by the semi-state agency in 2023 came with associated client spend commitments of €1.4 billion.  “With the requisite enabling conditions in place at a national level, aligned to emerging FDI attractiveness factors – such as AI skills and renewable, reliable and affordable energy – I think we will be well-placed to capture new investment opportunities,” O’Rourke says. A particular focus is Ireland’s future capacity to generate renewable energy – specifically, offshore energy. “We have been very vocal about the importance and potential of offshore energy. If Ireland gets its offshore energy strategy right – both fixed and floating – we could be in a surplus energy position in 10 years’ time,” he says. “That could transform our capacity to attract energy-intensive multinationals from various industries, because we would potentially be in a situation where have no constraints in relation to our ability to supply green energy.” O’Rourke is, he says, a born optimist. “When it comes to our strategy at IDA Ireland over the next five years, I do genuinely and fully believe that our best years are ahead of us.”