Financial Services Tax


Financial services tax

’Working in banking, insurance, investment management, leasing or securitisation?”

Deloitte’s global financial services Industry practices offer a wide array of services through our member firms that are specifically designed for financial institutions in the banking, securities, insurance and investment management. Recent market developments have caused the competitive and regulatory landscape to evolve at unprecedented speed. Financial services organisations now have to understand and tackle a more complex matrix of organisational challenges.

At Deloitte, we aim to go beyond the minimum requirements, leveraging our efforts to improve decision-making, cost, efficiency and service quality. Our specialist Financial Services team advises on complex issues, delivering highly innovative solutions to suit the particular needs of our clients. Our international Global Financial Services Industry network with its dedicated tax specialists enables us to respond to all cross border issues and provide appropriate solutions tailored for your needs.

Insurance Tax Insight: BEPS and the potential impact on the Insurance Industry

The final BEPS package, released by the OECD in October, has been endorsed by the G20 at their summit in Turkey on 16 November 2015. The thirteen actions are wide ranging and will impact all sectors of the economy including the insurance sector. The OECD intends to complete its work on the multilateral instrument to implement many of the BEPS actions and open it for signature in 2016. In this edition of the Deloitte Insurance Tax Insight series, we provide our view on BEPS and specifically those BEPS actions with the greatest potential impact on the insurance sector.

Download the report here

How we can help

Our Insurance tax team has substantial experience of both the international and domestic market and of the issues currently facing Irish insurance companies of all sizes. To assist with these challenges we have established, among others, dedicated Solvency II and IFRS 4 conversion teams. We follow an integrated approach to deliver tax services to clients operating within the industry in Ireland.

Our Insurance specialists operate across all areas of Tax, including Corporate Taxes, VAT, Capital Taxes and Global Employer Services groups when advising on client transactions.

Our services include providing advice on:
 •Tax Planning & Consultancy
• Tax Compliance
• Securitisation and Structuring
• Research and Development Tax Credits
• FATCA Implications
• Deleveraging, Mergers & Acquisitions (including Due Diligence)
•Transaction Structuring
• Transfer Pricing
• VAT Advisory
• The operation of withholding taxes in relation to the gross roll up regime, insurance premium tax (IPT), interest and dividends.
• IFRS and Solvency II Tax considerations
• Structuring of share based payments
• Tax efficient structuring and delivery of both remuneration and severance packages
• Freedom of establishment\ freedom of service tax advice
• Life wrappers
• Solvency II re-organisation\ cross border mergers

How we can help

Investment management
Navigating complexity from structuring to operational
We have extensive experience in helping you structure your fund tax-efficiently. Whether it is a UCITS, a non UCITS, a CCF or, indeed, an unregulated fund, our Tax specialists have the knowledge to guide you through the tax pitfalls.

The initial set up of the fund is the most important step and we can ensure all your fund documentation reflects best practice, is in line with tax authority requirements and achieves the required tax outcome. Minimising any tax leakage is a priority, so our team can work with you on issues such as VAT and withholding tax matters.

Recognising that many funds need to file for tax purposes in countries in which they are distributing, Deloitte can assist in such foreign tax filings (including the UK reporting fund regime and German reporting, for example).

In addition to working with fund promoters on product creation, Deloitte also works extensively with fund service providers on the tax issues that affect them including advice on setting up operations in Ireland and on-going tax compliance services. Investors' needs are also fully catered for by our specialists, who can advise on a range of matters, including the tax implications of any fund investment.

Our range of tax services includes:
• Fund setup, structuring, restructuring and re-domiciling, industry rulings and opinions in various jurisdictions
• EU and double tax treaty reclaims
• CCFs – local and international tax aspects
• Foreign tax filings
• Operational tax advice, including EU Savings Directive and FATCA
• Corporate tax: compliance and consulting services
• Transfer pricing advice
• VAT advice, including documentation reviews, advice on registration and recovery
• Payroll services, operation of PAYE, workforce transformation services
• Advice on transfer taxes affecting the fund and investors
• Research and Development tax advice, and
• Capital gains tax advice across multi-jurisdictions

Financial Services Tax

Banking and securities
Our Banking and securities tax team has substantial experience dealing with key taxation issues facing the Industry. We follow an integrated approach to deliver tax services to clients operating within the industry in Ireland.

Our banking and securities specialists operate across all areas of tax, including corporate taxes, VAT, capital taxes and global employer services groups when advising on client transactions.

Our services include providing advice in respect of:
• Tax planning and consultancy
• Tax compliance
• Restructuring of bank debt
• Asset deleveraging / optimising structure for acquisition of a loan portfolio (e.g. from NAMA)
• Securitisation and structuring
• Research and development tax credits
• FATCA implications
• M&A (including due diligence)
• Transaction structuring
• Transfer pricing
• Tax opinions and advice on bond/debt issuance
• Restructuring to minimise VAT and stamp duty costs
• Operational taxes including withholding taxes, DIRT, PSWT, TRS, and encashment tax
• Structuring of share based payments
• Tax efficient structuring and delivery of both remuneration and severance packages
• The tax implications of cash pooling arrangements

Financial Services Tax

Ireland is now one of the world’s major centres for cross-border leasing and offers very significant tax advantages to leasing operations.

Deloitte Ireland has a long established, diverse client base of leasing companies. We are delighted to work with some of the largest and most prominent leasing companies located here in Ireland. We are highly regarded by our current leasing clients in the field of tax, audit, and advisory having been actively involved in providing these services to the leasing industry over the last number of decades.
Working with our strong client base in the leasing sector, our services include:
• Maximising tax depreciation claims for lessors/lessees
• Developing structures that eliminate/ minimise foreign withholding taxes
• Asset securitisation and loan/lease portfolio securitisation
• Listing of leasing groups on public markets
• Development of new leasing products
• Accounting and taxation advice for structured finance transactions
• Advice on purchases and sales of aircraft
• Advising on how to obtain the 12.5% trading rate of corporation tax
• Development of VAT efficient leasing structures
• Documentation review
• Working with our clients and the tax authorities to introduce relevant leasing taxation legislation
Deloitte is a global player and a recognised leader in providing professional services to the leasing industry.  
Where a leasing company operates in numerous jurisdictions, international tax issues need to be considered. We can produce a combined report of the potential tax issues facing our clients in each of the jurisdictions they operate in.

Financial Services Tax

Deloitte is the recognised global leader in the area of securitisation with a dedicated team of senior professionals in over 40 countries providing a seamless service to the Financial Services industry. Clients can rely on our group of dedicated securitisation tax specialists in Ireland and across the globe, for thought leadership and creative thinking when analysing securitisation tax transactions.

Having recently been named ‘World’s Best Securitisation Accounting Firm of the Year’ by the International Securitisation Report for the 11th consecutive year, our in-depth industry knowledge and experience gained from advising over 12,000 transactions over the last 27 years is unmatched, and allows us to provide our clients with advice and innovative solutions of the highest quality.

Our highly experienced securitisation team are part of the Deloitte Ireland Securitisation Specialists cross functional team, including specialists in Corporate Finance, ERS and Valuations. The Deloitte Ireland team are also members of the Deloitte Global Securitisation team and the Deloitte Global Financial Services Industry Programme which consists of over 18,000 other highly qualified professionals in this area.

Together we can provide you with a comprehensive range of tax related securitisation services tailored to your specific needs. Some of the services we offer include but are not limited to the following;
• Assessing the tax effectiveness of your securitisation program
• Establishing and enhancing your tax accounting and risk policies and procedures
• Assessing your tax administration process
• Evaluating the fundamental tax implications of your particular transaction
• Feasibility Studies
• Structuring Advice (in particular on sophisticated and challenging structures)
• Documentation Preparation (including tax opinions, etc)
• Documentation Review (including prospectus’, collateral management agreements, administration agreements, etc)
• Tax compliance
In recent months, the Irish securitisation industry has undergone many changes, in particular those introduced by Finance Act 2011. Deloitte can advise and offer assistance and solutions in this regard having had much practical experience in this area.

Financial Services Tax

Foreign Account Tax Compliance Act (FATCA)
Countdown to compliance

On January 17, 2013, the US Treasury Department and the IRS released final regulations on the Foreign Account Tax Compliance Act (FATCA). Ireland and the United States signed an Intergovernmental Agreement (IGA) to improve international tax compliance with respect to FATCA  in December 2012.

Deloitte’s multidisciplinary FATCA team is focused on helping clients assess new or amended impacts and implications as well as pointing the way toward potential considerations

Financial Services Tax

Contact us

Deirdre Power

Deirdre Power

Head of Financial Services Tax

Deirdre is a financial services tax partner and is Head of the Financial Services Tax Group of Deloitte in Ireland and across EMEA. She is a Chartered Accountant with more than 20 years’ experience in... More

Pieter Burger

Pieter Burger

Partner - Tax

Pieter is a Partner in the Financial Services Tax department of Deloitte Ireland and currently leads the Irish firm’s Aircraft Leasing & Finance Tax Group. Pieter has more than 15 years’ experience ad... More

Conor Hynes

Conor Hynes

Tax Partner, Financial Services Tax

Conor is a tax partner with Deloitte, Dublin. Conor has more than 23 years’ experience advising clients in financial services and international tax. In particular he has advised extensively on transac... More