Ireland's new holding company regime

Journal
Bulletin for International Taxation 2004 (Volume 58), No. 12
Ireland and the European Commission reached agreement in September 2004 on changes to Ireland's new holding company regime, which then became effective retroactively from 4 February 2004. This article describes the new regime, including the changes that will be enacted in early 2005. Specifically, the article considers the two parts of the new holding company regime - a capital gains tax exemption and enhanced foreign tax credits for foreign dividends