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IFSC firm pays just Euro89,366 corporate tax on profits of Euro71m
Ken Griffin



IFSC-BASED company Lease Holdings, a subsidiary of the global treasury arm of car leasing giant LeasePlan, paid just Euro89,366 in corporate tax in 2005 despite making a pre-tax profit of Euro71m that year, an effective tax rate of 1.25%, the Sunday Tribune has learned.

The company, which owns several intercompany lending arms, reduced its taxation charge from the standard rate of 12.5%, which would yielded the Revenue Commissioners Euro8.8m, because a significant portion of its income came from dividend payments not subject to tax.

The firm's income jumped from Euro3.1m in 2004 to Euro141.5m in 2005 and it paid a dividend of Euro100m to a parent company in the Netherlands, where LeasePlan has its headquarters. The company has no employees, although LeasePlan global treasury employs 19 people in Dublin.

LeasePlan's senior corporate vice president and group treasurer, Bas Snijders, said the company had decided to transfer the capital out of Ireland because its Dublin operations were overcapitalised.

"If you look at capital management throughout our group, you put it where it makes sense and works best, " he said.

Snijders said the Dublin companies were responsible for financing LeasePlan's operations, and acted as an inhouse bank to most of the company's subsidiaries throughout the world.

"We manage two balance sheets from Dublin: LeasePlan Finance for countries where Irish double taxation treaties are favourable, and LeasePlan Corporation, a Dutch bank, for countries where Dutch double taxation treaties are favourable."

Despite the company's low tax liability, Snijders said that while the company had set up its treasury operations in Dublin ten years ago to take advantage of the special 10% corporate tax rate then offered at the IFSC, it was not the sole factor behind its continuing presence here.

"We've had a look at Dubai, where the corporate tax rate is 0%, but Dubai isn't Dublin.

Issues come into play such as recruiting and retaining skilled staff, " he said. "What we have done over the past couple of years is establish a treasury operation in Ireland, which is not something you can move easily."

However, Sheila Killian, a lecturer at the Kemmy Business School at the University of Limerick, said she was concerned that companies such as Lease Holdings were assisting opponents of Ireland's low corporate tax regime in Europe.

"Germany and the Netherlands, for instance, are losing profits to companies like this in the IFSC. This kind of company is stoking up the attack on our corporate tax system, " she said. "It gives momentum to backers of the common EU tax rate because it is clearly pooling profits and income from other EU countries with little benefit to Ireland."

She said she was also concerned that the continuing presence of companies with zero employees at the IFSC was damaging its reputation abroad.

"The IFSC is starting to be seen in the same light as the Cayman Islands and Jersey.

This is not good for the sustainability of the centre."




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