pre-budget 2020 · 2019-11-15 · delivering workplace agility, ... reports11 with an enterprise...

@americanchamber | #USIRL19

Pre-Budget 2020 Perspective

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‘For talented individuals to choose Ireland as their long term base, their choices will be driven largely by the quality of the experience of their lives here – be it housing, transport infrastructure, healthcare and education.’Mark Gantly, President of the American Chamber of Commerce Ireland, July 4 Leadership Summit speech

PRE-BUDGET 2020 PERSPECTIVECONTENTS

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Prioritised Infrastructure

Investment

Personal Tax Roadmap

Enhanced Innovation Investment & Incentives

Human Capital Investment

Strengthen Ireland’s Corporate

Tax Roadmap

Trade Promotion and World Class Competent

Authority Investment

The American Chamber of Commerce Ireland | Pre-Budget 2020 Perspective

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AMBITIONIreland as an inclusive location-of-choice for Talent and Innovation with Global Impact.

COMPETITIVENESSAccelerating Delivery

Fostering Talent

Increase Productivity

RESILIENCEFiscal Sustainability

Policy Certainty

Business Flexibility CONTEXT:

INVESTMENT UNCERTAINTYTrade Tensions and Brexit

Slowing Global Economy

Changing International Tax Landscape

Disruptive Digital Upheaval

Climate Action

RESILIENCE:

Fundamental Conditions

Ireland is a full-fledged global partner of American business— a critical linchpin in the global success to some of the world’s most innovative and successful firms. Attributes that have provided the basis for this reputation include:

Fiscal Sustainability

A secure fiscal position provides the foundation for confidence in the future of the Irish economy as a place to live, work and invest. Further improvements in the fiscal position should be deployed to accelerate progress in building sustainable competitiveness for the traded sector with budgetary and investment decisions aimed at improving national productivity.

Policy Certainty

Policy certainly positively encourages investment. The Chamber welcomes the certainty given on Ireland’s Corporate Tax Road Map and the restatement of Ireland’s sovereignty and decision-making authority in relation to corporation tax policy. We also welcome the reaffirmation of the principle of unanimity at EU level in relation to taxation matters.

Business Flexibility

Remaining nimble and responsive to a highly uncertain and fast changing global environment is key to competitiveness. The existing voluntarist industrial relations environment, the best practices of its modern sector, and the existing and reformed industrial relations frameworks are serving the country well by delivering workplace agility, stability and productivity and is vital to winning mobile investment.


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Investment

"Finding accommodation is a big issue to attract talent to Ireland. We need to be more attractive than competitor cities- Barcelona, Amsterdam and London - to justify increasing our footprint in Ireland."

– Site Lead, Global ICT Company

1 Ireland’s Competitiveness Challenges – National Competitive Council (Dec 2018)2 Published by INRIX in February 2019 – see www.inrix.com3 IMD World Competitiveness Rankings, May 20194 EU Digital Economy and Society Index (DESI), June 20195 Government 10-year €116 billion investment plan and planning framework. See: https://www.gov.ie/en/policy/project-ireland-2040-policy/

Prioritised Infrastructure Investment

Housing:

‘The state of the housing market is a major impediment to attracting talent and investment and improving Ireland’s competitiveness performance and the quality of life of its citizens. The urgency and scale of the housing challenge and the complexity of the market require not only providing sufficient funding but also deploying innovative solutions and interventions by the State.’National Competitive Council – Ireland’s Competitive Challenges1

Access:

‘When examining Hours Lost in Congestion metric, Dublin (246hrs) was the third-worst city (of 200 cities from 38 countries analysed), while Galway (44hrs) ranks on par with Berlin, Hamburg and Stuttgart.’ INRIX Global Traffic Scorecard Report2

Quality of Physical Infrastructure:

‘Ireland’s very strong competitiveness performance globally (7th) is restrained by poor and weakening scores for infrastructure (23rd), including the perception of basic infrastructure (35th) and maintenance and development of infrastructure (35th).’ IMD World Competitiveness Rankings3

Digital Infrastructure:

‘Ireland is the 7th (+1) most advanced digital economy in the EU, up from 9th place in 2017. A key weakness is connectivity, as availability of ultrafast broadband coverage (21st) is below EU average and relatively expensive (24th).’ EU DESI Index 20194

Recommendations

• Accommodation: Resource the Land Development Agency and Planning Authorities and Renew the Strategic Housing Development Scheme.

• Project 20405: Place ‘Delivery Board’ leadership within the Department of An Taoiseach, Review and Expedite identified Pro-Employment Projects and Planning Process Certainty.

• Region Balance: Drive Atlantic Economic Corridor (AEC) development, Align Priority Regional Infrastructure with recommended Project 2040 Review, Expand Portfolio of available Grade One office space and Advanced Technology Units.

• Digital: Rapid National Broadband Plan delivery and greater Digital Innovation and Use in the delivery of Public Services.

• Utilities: Improved Electricity Interconnection and Competitive Water Infrastructure Delivery.

Ireland must make the right choices for the long term. Invest in housing; improve roads and rail; access to faster internet, for every region.


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The leadership of the American Chamber are strongly

of the view that a step-change in the pace of delivery

of strategic and pro-employment physical and digital

infrastructure is necessary to maintain Ireland’s

competitiveness and address critical risks to economic

well-being.

The American Chamber has consistently called for a

scenario-based approach to reviews of planning and

capital spending depending on the developing patterns

of economic and population change. During the life

of the National Planning Framework, reviews should

be triggered by changes to strategic assumptions

underlining the analysis and guidance, not by the

passage of discreet time intervals. Uncertainties driven by

Brexit, international trade and taxation regime upheavals,

urgency around climate change and the quickening pace

of digitalisation warrants consideration.

The American Chamber strongly supports Government

initiatives to strengthen institutional and political focus

on delivery. To further this ambition the American

Chamber recommends placing the responsibility and

leadership for the Project 2040 Delivery Board6 within

the Department of An Taoiseach, supported by a fully

resourced Investment Projects and Programmes Office.7

To ensure that Project 2040 is attuned with emerging

competitive threats the American Chamber recommends

that Delivery Board review project priorities and make

recommendations to expedite identified critical pro-

employment infrastructure projects in light of Ireland’s

2019 National Risk Assessment Report8 and the National

Competitiveness Councils next ‘Ireland’s Competitiveness

Challenge’9 report.

The American Chamber recommends that responsibilities

of the Delivery Board should include: examining

benchmark analysis of Ireland against other jurisdictions

for planning and delivery; making recommendations of

proportionate changes to the planning process to narrow

the differentials; suggest measures to improve certainty

over the planning process and the length of time

between planning application, to approvals and eventual

delivery of the project. Government’s ambition for an

upgraded Investment Project and Programme Tracker10

should consider how to demonstrate to enterprise

dependency relationships between activities, current

schedule status including variances and the reasons they

occurred. A brief quarterly update to Project 2040 Annual

Reports11 with an enterprise and investor lens would be

welcome. As increasing capacity and delivery times is an

imperative, the American Chamber supports investment

in promoting project tenders to potential bidders/investor

markets outside of Ireland.

Building on the clarity of the planning framework and

investment plan within Project Ireland 2040 as a basis for

sustainable long-term strategic growth for the country,

the American Chamber believes that Ireland should aim

to be recognised as the best place to work and live. The

American Chamber agrees with the National Competitive

Council; Ireland’s competitiveness challenges require

a sustained, strategic and co-ordinated focus across a

wide range of policy areas to improve the productive

capacity of the economy. Setting a long-term capital

investment goal of +3% of GDP to support economic

and demographic growth; targeting priority areas such

as the provision of affordable; accessible and quality

accommodation and quality public services; is key to

future proofing the resilience of the economy.

Accommodation:

The American Chamber welcomed the connection

made between housing and Ireland’s ability to remain

internationally competitive in attracting and retaining

talent in the planning framework for Project Ireland

2040. The American Chamber is strongly of the view that

the provision of accommodation is a critical economic

enabler that requires continued prioritisation for planning

and capital investment. This is especially true in Dublin,

with similar needs for designated urban centres of scale.

The cost competitive, and innovative, delivery of

housing commitments is imperative if Ireland is to

remain a location that retains and attracts world class

talent. The American Chamber supports the investment

plans and reforms within Government’s Rebuilding

Ireland12 action plan aimed at increasing the delivery of

homes nationwide. Ancillary facilities - such as schools,

affordable childcare, roads and transport access are

also viewed as essential requirements for employment

growth. The establishment and resourcing of the National

Regeneration and Development Agency is welcome in

so far as it expedites the supply of State-owned land for

long term residential community development.

Furthermore, supporting agencies such as the Office of

Public Procurement should be adequately resourced to

strengthen the mission of the new Agency. Measures to

encourage the pooling of planning resources between

local authorities, the acquisition of expertise to deal with

planning bottlenecks and the renewal of the Strategic

Housing Development Scheme13 would be strongly

welcomed by American Chamber members.

The American Chamber is very supportive of initiatives

to improve the flow and development of skills into the

construction delivery sector. Increasing economies of

scale opportunities via standardisation and consolidation

of public procurement across local authorities should

be supported. In addition, the application of LEAN

process improvement for project management, use

of new construction technologies including best-in-

class construction digital information tools, and use of

appropriate prefabrication solutions.

Infrastructure in Ireland’s Flagship Centre of

Scale: Dublin

Investment is needed to develop Dublin as a recognised

flagship metropolitan city; serving as a beacon for the

entire country’s attractiveness. Cities and urban areas

are increasingly the preferred locations for high-tech

companies’ start-ups; largely because of the increased

preference of highly skilled tech workers for such

locations.

Dublin is a transatlantic magnet for internationally traded

services and digital media investment and the American

Chamber expects this demand to continue if the

economy can absorb that opportunity. Transit congestion

impacts competitiveness. Dublin needs certain and

reasonable travel and transfer times, around the city, its

orbital route and the main arteries. The resourcing and

speedy delivery of the Bus Connect programme and

cycle network is key goal for improving the commuting

experience of those living and working in the City.

The American Chamber encourages the on-time and

on-budget delivery of existing commitments on Metro-

North, expanding Luas cross-city and the delivery of

Dublin Airport’s new runway to provide needed extra

connectivity capacity. Planned enhancements to the

M50, greater use of high-speed bus corridors and the

expanded capacity on existing rail/light-rail services have

important contributions to make to easing congestion.

In the medium-term the consideration of new orbital

routes to connect suburban and commercial centres

should seek to reduce the use of the M50 for shorter

interconnections, allowing it to serve its main function in

taking traffic away from the city centre.

City Regions: Balanced Island Development

The American Chamber welcomed the balanced

regional development proposed in Project Ireland

2040. Economic development and renewal should be

focused around urban centres of scale, requiring greater

urban densification and metro transport capacity. The

American Chamber believes that the regions provide a

balance to Dublin; encouraging talent to locate in areas

with good regional and international connectivity, and

affordable housing.

The American Chamber supports the Atlantic Economic

Corridor14 concept and efforts to capitalise on the

substantial amount of activity and investment taking


Investment

6 Established in 2018, comprising top officials from relevant Departments and Agencies and currently jointly chaired by the Secretaries-General of the Department of Public Expenditure and Reform (DPER) and the Department of Housing, Planning and Local Government (DHPLG) the Delivery Board monitors implementation structures and performance across the various sectors to ensure a co-ordinated and collaborative whole-of-Government approach to NDP and NPF delivery.

7 Presently within the Department of Expenditure and Public Reform8 See Draft 2019 Assessment here: https://assets.gov.ie/9294/d5b7898a4d8e47d1a7ff1d9efc6e1e53.pdf9 Ireland’s Competitiveness Challenge identifies a range of recommendations that address both immediate competitiveness issues,

and more medium-term challenges, aimed at enhancing Ireland’s competitiveness and productivity performance. See : http://www.competitiveness.ie/

10 See: https://www.gov.ie/en/publication/6db7c4-investment-projects-and-programmes-tracker/11 See: https://www.gov.ie/en/publication/b684c6-project-ireland-2040-annual-report-2019/

12 See http://rebuildingireland.ie/ 13 Since July 2017 planning applications for housing developments of more than 100 residential units and 200 plus student bed

spaces can now be made directly to An Bord Pleanála.14 The Atlantic Economic Corridor (AEC) is a Government-led initiative in regional development, complementing and balancing

Ireland’s thriving East Coast - a non-administrative or “linear” region along the Western seaboard, stretching from Kerry to Donegal. https://www.atlanticeconomiccorridor.ie


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"We need to attract highly skilled specialists from our global company network for future business wins. High rates of personal tax could deter them." – Country Manager, Medtech Firm

place at individual county level along the west coast

with a view to driving increased amounts of domestic

and overseas enterprise investors. The attractiveness of

each ‘City Region’ can be enhanced by the completion of

the broadband network, the development of Grade One

office space, and Advanced Technology Units for rapid

turn-up of new manufacturing, service, supply chain and

R&D operations.

Southern & Western Priorities: Building on the significant

enhancements to the road network linking the capital

with the main cities of the west and south, the following

projects within the Project 2040 are vitally important

opportunities to enhance physical connectivity;

In Munster

• The delivery of the M20 project between Cork and

Limerick would significantly enhance the Atlantic/

Western economic corridor by linking population

centres, industrial clusters, ports and air hubs

and thus improving regional connectivity and

competitiveness to retain and attract investment.

Proposals for the N28 Cork to Ringaskiddy motorway

must be delivered in a timely manner to support

high-tech life science investment in that important

manufacturing and development hub.

In Galway

• Advancing the N6 Galway City Transport Project,

especially improved access to Parkmore’s industrial

zone.

Northwest Accessibility: The American Chamber

acknowledges the special attention that the Northwest

Region received in the National Planning Framework

considering the risks arising from Brexit. The region is not

well connected to Dublin or international airports. The

development of the A5/N2 between Derry and Dublin

remains the priority for American Chamber members

in the region. The American Chamber notes that the

following are priority short to medium term projects:

• The N14 Letterkenny to Lifford route with connectivity

to the A5 (with supporting improvement and bypass

projects) to dual carriageway standard;

• In Sligo, while the N4-M4 route upgrade to dual

carriageway standard remains the objective, the

timely delivery of the N4 Collooney to Castlebaldwin

development is greatly anticipated.

• A step forward in connectivity of the midlands and the

West will be achieved with the completion of the N5

upgrade.

Ireland’s Digital Leadership

Ireland is well placed to further enhance its reputation

for digital leadership in Europe. Sustaining Ireland’s

leadership requires a best in class ecosystem with

ubiquitous national broadband coverage as a vital

necessary condition in our knowledge-intensive

economy to avoid digital, and thereby economic,

blackspots. The American Chamber supports the speedy

implementation of the ‘National Broadband Plan’ to meet

the Government’s ambition of ensuring that the entire

population has access to quality, competitively priced

fibre-based broadband services as rapidly as feasible.

This infrastructure can be transformative in how citizens

engage with government in accessing services. It will

require state alignment with long term economic and

industrial planning that actively exploits public-private

opportunities for data-driven innovation and world class

cloud use.

Competitive Utilities

Energy: Investment is required to ensure adequate

regional/local capacity to support investment

locations; especially in the main urban centres. Greater

interconnection is a key priority, including the delivery of

the all-island North-South Interconnector and the Celtic

Interconnector to mainland Europe to ensure energy

security and generation diversity. Consideration should

be given to extend the country’s gas infrastructure

network, to include penetration into the centres of the

Northwest to improve their attractiveness for investment

and incentives to encourage development. More widely,

the utilisation of combined heat and power assets, LEAN

energy & CO2 processes and renewable energy sources

such as bio-gas should be encouraged.

Water: The American Chamber continues to support

efforts to develop and resource a strategic approach

to water services and management that is competitive

for commercial users. Future inward investment

opportunities will arise with more certainty as to water

availability, quality, treatment capacity and price

competitiveness. A sustained commitment to capital

expenditure is required to secure quality and affordable

provision to industry. Dublin’s critical capacity constraint is

a risk to future industrial as well as population growth and

must be addressed with urgency.

Ireland's tax regime should remain internationally competitive to retain and draw expertise from overseas.



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‘From a competitiveness perspective, it is essential that the taxation system is broad and balanced in a way that supports both indigenous and foreign enterprises, rewards investment and entrepreneurship and encourages people to take up employment.'National Competitive Council – Ireland’s Competitive Challenges15

‘Consideration may be given to a broader review of personal income taxation to better reward work ... the relatively high marginal tax rate faced by high income earners is an impediment to international competitiveness and a disincentive to attract skilled labour from abroad.’ International Monetary Fund: Ireland 201816

“ … single earners in Ireland face among the highest marginal tax rates in the EU. … a very high marginal tax rate in Ireland is reached at a relatively low point in the income distribution.’ European Commission’s Economic Brief17

‘Based on most recent OECD data as at June 2019, the average rate of income tax and social security as a percentage of total earnings shows the Irish regime to be the second highest in the competitor sample group including the Netherlands, Switzerland, Singapore, the UK and the USA.’ OECD Taxes on Labour Database 201918

‘Ireland’s high rate of marginal taxation on income plays an increasingly important part in an individual’s decision-making process. The fact that many of competing EU countries have schemes offering reduced levels of personal taxation for talented, mobile individuals serves to exacerbate this problem.’ National Competitive Council – Ireland’s Competitive Challenges19

15 Ireland’s Competitiveness Challenges – National Competitive Council (Dec 2018).16 IMF June 2018 Article IV Staff Report, IMF17 Personal Income Tax in Ireland, Economic Brief 028, July 201718 An American Chamber comparative analysis using OECD Taxes on Labour Database, June 201919 Ireland’s Competitiveness Challenges – National Competitive Council (Dec 2018).

Recommendations

• Personal Tax: Reform high marginal thresholds and rate to reward and attract talent.

• Share-Based Remuneration: Apply a capital gains regime on realisation of Share-based Remuneration.

• Pension Provision: Index link Contribution Thresholds to the Consumer Price Index (CPI) annually.

• Special Assignee Relief: Enhance Access by extending the 5-year term.

• Business Travellers: Aligning policy to pre-2018 position for Incidental and Business travel.

20 https://www.amcham.ie/Advocacy/Policy-Work/Submissions.aspx?page=3

The American Chamber welcomes the Government’s

continued commitment in recent Budgets to lower

personal taxation – a key recommendation of the

American Chamber. A competitive personal tax regime

is an important deciding factor for global talent who can

choose where they wish to locate to develop their career.

As we have previously stated in past submissions, the

marginal personal income tax rate (together with PRSI and

USC) with its low entry threshold should be reformed to

enhance Ireland’s ability to retain and attract leadership

talent and specialised skills, improve productivity and

reduce upward pressures on labour costs.

Members of the American Chamber continue to identify

Ireland’s high marginal income tax rate as a dissuasive

factor in the retention and attraction battle for advanced

skills and leadership experience. This vital talent pool is in

short supply globally, and both employees and potential

recruits are being attracted to jurisdictions where their

total income tax and social security is lower – often

significantly so. The current higher marginal income tax

rate of 52%, when one includes PAYE/PRSI and USC,

is among the highest when compared with countries

that Ireland currently competes with for investment. The

relatively early entry point that income is exposed to the

highest marginal personal tax rate is uncompetitive for a

traded economy reliant on a highly mobile labour market

within Europe.

As a location of choice for international business,

Ireland’s personal tax regime is assessed considering

OECD international tax reforms and redesigned transfer

pricing rules. The reforms seek a greater alignment of

taxable profits with the location of economic substance

and value creation, with specific focus on the location

of functions, assets and risks. With respect to business

value derived from intangibles, post BEPS, corporate

profit allocation will have greater alignment to where the

significant elements of the development, enhancement,

maintenance, protection, and exploitation of intangibles

(DEMPE functions) is carried on. This drives a focus on

people functions related to the DEMPE functions, and

less on contractual terms and capital. The identity of

the member or members of the multinational group

performing such functions is now to become a key

consideration in determining which entity or entities

ultimately will be entitled to (and thereby subject to tax)

returns derived by such groups. As a result, business

will seek to structure their business models and the

location of group assets (including intangible assets)

with where economic substance, including the DEMPE

functions, is located or can be relocated with a focus

on key decision makers vital to the functioning of the

business operation. Attracting or retaining this operational

substance, especially key people related to DEMPE

functions, and business expertise and related activity

in a post-BEPS environment will be intrinsically linked

with the corporation tax take in the future. Therefore, it

is imperative that income taxation policy does not inhibit

Ireland as a location of choice for such leadership and

specialised talent.

Personal Taxation Roadmap: The American Chamber is

strongly of the view that reform should continue to be

central to Ireland’s ambition to reward existing talent,

encourage émigrés back to develop their careers and

ensure that working in Ireland is a rewarding proposition.

The American Chamber supports reforms focused

on rewarding productivity by providing direct relief

to individuals by increasing the entry point to the top

marginal income tax rate and by reducing the current tax

rate to below 50% on a phased basis of 1% per annum

over the coming years.

By targeting the following additional areas, the American

Chamber believes that the ability of our members to

attract and retain critical technical and leadership talent

within the jurisdiction would be significantly enhanced.

Taxation of Share Based Remuneration: The American

Chamber made a submission to the Department of

Finance as part of the 2016 public consultation on the

Taxation of Share Based Remuneration20 which remains

relevant for this and future budget reforms. At its core

is the recommendation that the personal tax treatment

of shares acquired under all share-based remuneration

arrangements (e.g. share option schemes, Restricted

Stock Units, etc.) should be enhanced by removing

the personal income tax charge on the acquisition/

granting of such remuneration in favour of a capital gains

charge on the realisation of the share-based income

to the individual. This remains the Chamber’s primary

recommendation for policy change in this area.



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the American Chamber believes that a commitment by

Government to index link the thresholds would be a more

equitable way of ensuring that the limits are annually

revised to ensure the real value of the current limits are

maintained at current levels and not diluted over time.

Thus, the American Chamber strongly recommends

that the individual’s Personal Fund Threshold and the

Standard Fund Threshold should be increased in line

with the Consumer Price Index (CPI) and this indexation

should henceforth occur automatically each year.

In addition, employers would be wholly opposed to

any change which would give rise to a restriction in

the age-based thresholds and annual earnings cap

which determine the maximum pension contribution of

an individual qualifying for income tax relief. Any such

amendment would only serve to further dis-incentivise

individuals from contributing to the funding of their

future pensions. Consideration should be given to

relieving measures where employees take unpaid leave

and the Chamber would be happy to discuss further with

the Department.

Professional Subscriptions: In the context of Ireland’s

knowledge economy, industrial employees membership

of professional bodies is a necessity for many businesses

and should be eligible for tax relief, without triggering

benefit in kind implications. The Chamber would be

happy to discuss with the Department further.

Foreign Earnings Deduction: The Foreign Earnings

Deduction provides tax relief from income tax for

individuals who are resident in the State but

temporarily carry out their duties in specific countries.

The American Chamber recommends that the Foreign

Earnings Deduction relief be extended to include more

emerging markets.

Reciprocal social security arrangements: Ireland currently

has several social security arrangements in place with

key jurisdictions including Canada, Japan and the United

States. The American Chamber recommends that the

number of reciprocal social security arrangements be

extended with key trade partners including jurisdictions in

the Asian markets.

Capital Gains Tax Exemption: The American Chamber

recommends an increased CGT exemption for an

individual from the current limit of €1,270 per annum

given its current deminimus level.

21 See: American Chamber Pre Budget Submission 2018 https://www.amcham.ie/advocacy/policy-work/submissions.aspx 22 IMF, 2018

The American Chamber believes that certain

amendments to the current taxation treatment of share-

based awards could, in conjunction with other reforms

to Ireland’s personal tax regime, significantly enhance

Ireland’s overall FDI offering by rewarding productivity.

Moves to enhance the taxation of share-based reward

in 2018 with the introduction of the Key Employee

Engagement Programme (‘KEEP’) targeted at small

growing enterprises are welcome. This is an area of

significant importance for a wide range of our members,

but is significantly relevance to the new and emerging

FDI players wishing to use share incentives effectively to

attract and reward talent that take on the risk associated

with joining a start-up or scaling-up organisation with

finite cashflow resources.

For Budget 2020, the American Chamber puts forward

several measures to build on previous reforms including:

• Enhance the programme by providing a safe harbour

limit with respect to share valuations.

• Remove the exclusion on certain companies from the

KEEP scheme, in particular technology companies

that are also carrying on financial activities.

• Enhancing the KEEP scheme by revising the limits

imposed in respect of employee numbers, turnover

and balance sheet valuation.

• Revise the requirement for a qualifying individual to

be a full-time employee in order to avail of the relief

to incentivise high skilled workforce re-entry.

• Extending the relief where existing shares are

granted, rather than only to new shares.

• Improve the tax treatment of all share-based

remuneration arrangements by removing Employee

PRSI and the USC.

• Reduce the CGT rate from its current level of 33% to

maintain the competitiveness of the current KEEP

regime in comparison to other jurisdictions;

Assignee Program:

The American Chamber supports Government initiatives

aimed at attracting specialised talent and leadership

executives to relocate to Ireland with an aim of bringing

with them investment and employment. To continue

to make competitive enhancements, the American

Chamber suite of recommendations made in its

Pre-Budget Submission 201821 remain highly relevant.

The Chamber would be pleased to discuss these with

the Department.

Positive steps forward in Budget 2020 would include:

• An assessment as to whether the 5-year relief

term under SARP should be extended to remain

competitive with other jurisdictions.

• The requirement for a relevant employee to have

been employed for a period of 6 months prior

to assignment can in certain instances preclude

individuals employed in the technology and

knowledge-based sectors from qualifying and

should be reviewed.

• An assessment as to whether the threshold of

€75,000 renders the Irish regime uncompetitive

by comparison with other countries.

• Application of the relief to USC and PRSI, in addition

to income tax.

Business Travellers: Business travellers are key to any open

economy which hopes to attract inward investment and

generate increased export activity. These travellers include

those who travel from US parent companies for meetings,

for short projects or to provide experience and guidance

to Irish staff. While the American Chamber welcomes

Revenue’s work in providing clarity on the regime’s

operation our member’s considers competitor jurisdictions

such as the UK and Switzerland as having more favourable

and practical laws in place for business travellers.

Accordingly, the American Chamber is of the view that if

the original practice cannot be restored within the context

of existing legislation then consideration should be given

to legislating to re-establish previous practice of allowing a

30-day annual exemption for those travelling to Ireland in

consecutive years from a DTA country.

Pensions Policy: It is of the utmost importance that

pension policy changes do not adversely impact the

sustainable competitiveness of doing business in Ireland

and employers’ ability to retain experienced leadership

talent for Irish based operations. While a one-off move

to a higher threshold would be a more impactful option,


Consideration may be given to a broader

review of personal income taxation to

better reward work.22


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All of the conditions are present for Ireland to be a world innovation leader, if we remain competitive.

23 EU Commission Innovation Scoreboard, June 2019 https://ec.europa.eu/growth/industry/innovation/facts-figures/scoreboards_en

24 OECD Science, Technology and Industry Policy Papers No 32 2016

Enhanced Innovation Investment and Incentives

‘Ireland ranked 35th for R&D spend at % of GDP.’ IMD 2019 World Competitiveness Rankings

‘Ireland's economy has been ranked 14th in the world for innovation including 32nd for research intensity placing it behind Switzerland, Singapore, Austria and the USA.’ Bloomberg Innovation Index 2019

‘Ireland’s lowest indicator scores comprise R&D expenditure in the public sector.’ European Innovation Scoreboard 201923

‘Many of the strongest empirical studies that have been conducted throughout OECD countries over the past two decades show that research and development significantly improves firms’ performances, however measured. The economic performance of a country thus depends on its capacity to provide the right incentives to encourage R&D investment.’ Organisation for Economic Cooperation and Development24

Recommendations

• Knowledge Intensity: Raise investment in SFI, establish a world class Advanced Manufacturing Centre of Excellence and extend the Disruptive Technologies Innovation Fund to include public service delivery challenges.

• R&D Credit Regime: Expand limits for providing contracted R&D services. Administration clarity and consistency.

• IP Regime: Improve competitiveness for acquiring IP and continuance of the Knowledge Development Box regime.

The American Chamber believes that Science

Foundation Ireland’s (SFI) focus on “Excellence and

Impact” is a sound strategy for inward investment.

Public investment should seek to retain the current RDI

investment in scientific excellence, as well as providing

additional resources to improve research centres of scale

focused on the application of knowledge and technology.

Having a renowned and internationally recognised

centre of excellence in advanced manufacturing would

underpin Ireland’s ambition to continue to design, supply

and support the delivery of goods and services to

global markets.

The American Chamber is very supportive of the

Disruptive Technologies Innovation Fund to address

the national policy challenges as a ‘Challenge-Centric’

method for aligning innovation investment with public

priorities. For future calls, the American Chamber

recommends that Government formulate criteria

for funding calls that promote industry leadership,

encourage MNC-SME-HEI linkages and builds on

established eco-system strengths to deliver projects of

measurable impact within 3-5 years that include public

service delivery challenges.


"Incentives are one of the main factors we use when determining how we allocate resources in Europe"

– Chief Executive, Financial Services Company


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25 https://www.amcham.ie/advocacy/policy-work/submissions.aspx

The leadership of the American Chamber of Commerce

Ireland are firmly of the view that the R&D tax credit

regime has been, and can continue to be, a critical tool in

ensuring that Ireland is competitive for research, product

development and process innovation projects.

The regime encourages companies to undertake high-

value-add R&D activity in Ireland and thereby supports

wider investment and employment. It is now an integral

part of Ireland’s corporate taxation proposition to retain

and attract this investment. Member feedback suggests

that within the knowledge intensive sectors some 37%

of the total employment base is dependent on the

existence of a competitive R&D tax credit regime.

Small open economies are increasingly competing

against each other in access to talent and global

innovation leadership in business, science and

technology. Inward investment is key to the R&D

ecosystem in Ireland; 69% BERD (Business Expenditure

on Research and Development) in Ireland is by foreign

companies. Research shows that tax incentives have a

clear advantage over direct funding FDI investments and

tax credits have become an increasingly popular method

of driving R&D investment across OECD countries. It is

vital that Ireland continues to have an R&D incentive

program that matches or exceeds the best available

to ensure that we remain globally competitive and

continues to attract the best R&D investment.

The Chamber outlined its views on the 2019 Review

of the R&D Tax Credit Regime as part of the recent

public consultation.25 Key recommendations for

enhancements included:

• Increasing the current limits imposed on third party

payments for providing contracted R&D services.

• Altering the R&D tax credit refund mechanism to

facilitate the offset of the refund arising from the R&D

tax credit against other taxes.

• Amending Section 766 TCA 1997 to delete the

term “wholly and exclusively in the carrying on ... of

research and development” and replaced with “for the

purposes of research and development.”

• Leveraging the State’s own technical resource as per

the IDA’s grant assessments to review the technical

basis of R&D tax credits claims would assist in this

alignment and allow reduced administration.

• Amending R&D legislation to ensure that certain

costs incurred in undertaking a qualifying R&D activity

under the general framework of S.766 TCA 1997

should be allowable.

• Recognising that to support global R&D projects the

regime needs to recognise how Irish subsidiaries

engage with connected parties (i.e. parent companies

in the US).

• Evolving the regime, while remaining based on

the OECD Frascati model, to expand the qualifying

fields of science to emerging areas (e.g. such as

the interaction between technology and human

behaviour).

• Clarifying the level of novelty required to be sought

in the Irish regime to reflect conditions on the ground

and to allow Irish companies to continue on the path

from ‘D’ to ‘R’ over time.

• Allowing an administrative innovation to provide an

election option for the R&D credit regime to allow

claimants with a tax base to forgo corporate tax

deductions and take the benefit foregone by wa

of R&D credit.

• Including the research and development costs

associated with contributions to standards

development as a pathway to encourage ‘standards

by design’ amongst enterprise.

Intellectual Property (IP)

The American Chamber believes that the continued

enhancement of Ireland’s IP offering is critical from an

Irish tax policy perspective to create an environment

where Ireland can compete for mobile IP

related investment.

IP amortisation regime: The Government and Department

of Finance have stated that they regard Ireland as having

a suite of offerings to attract knowledge intensive activity

to Ireland from an IP perspective. The Irish IP amortisation

regime (included in Section 291A TCA 1997) is a key pillar

within this suite and there are several areas where the

American Chamber believes enhancements should be

made in order to improve competitiveness and attract

further IP related investment. These recommendations are:

• Amendments to provide that there is no claw-back of

IP amortisation allowances previously claimed.

• Provide further guidance (potentially certain “safe

harbour” tests) in relation to what activities should be

regarded as trading in an IP context.

• Amend the definition of “specified intangible asset” to

include goodwill where such an amount is amortised

for accounting purposes.

• The current requirement included in Section

291A to regard the income and expenditure from

qualifying IP as a “separate trade” from an Irish tax

perspective causes several practical issues for

some of our Members. In this context, the American

Chamber would recommend that the impact of this

requirement is fully considered in conjunction with

any potential costs that would be associated with

removing this requirement with a view to ascertaining

whether the removal of the “separate trade”

calculation could be a worthwhile enhancement to

Section 291A. The American Chamber would be more

than happy to discuss this issue in more detail

as required.

• The accounting for amortisation regimes (such as

Ireland’s) under US accounting principles is a complex

area. In several instances, this is a key issue for our

Members. The American Chamber recommends

that the Government considers whether the IP

amortisation regime could be amended to deal with

these challenges. Further, most Irish companies who

prepared financial statements under ‘old Irish GAAP’

were obligated to convert to FRS 100/101/2012.

These new accounting standards require companies

to ‘fair value’ certain assets, including IP. In effect, this

means that such assets may no longer be amortised

on an annual basis, and thus companies who claimed

relief under Section 291A on the amortised basis may

lose the relief if the law was to remain as is. In this

context, it is evident that Section 291A may have to

be amended technically in any event such that it is

now timely for a review of the section for this and the

above-mentioned US accounting issue. The American

Chamber would be happy to explore these issues

further with the Government and the Department of

Finance as required.

This area is of key importance in a post-BEPS

environment and the American Chamber would be

happy to consult further with the Department on any

change not outlined above.

The American Chamber would also welcome

further consultation on opportunities to enhance the

competitiveness for IP related investment.

Knowledge Development Box (“KDB”): The American

Chamber was a key contributor to the consultation

process initiated to consider the creation of a

‘Knowledge Development Box’ (KDB) regime for Ireland.

It is imperative that Ireland continues to illustrate its

competitive and certain tax regime for IP development

and exploitation in Ireland. Understanding the necessity

for reviewing tax expenditures requires an "end date" for

the KDB, it would be important for investor certainty that

the Minister makes a positive statement in Budget 2020

that the intention would be to evaluate the incentive

at that point for its ‘fitness-for-purpose’. Further, the

relief currently applies to accounting periods which

commence before 1 January 2021 and confirmation of its

continuance after that date would be welcomed.



20 21

Ireland can stay ahead of the game, deliver faster results, foster talented people, and demonstrate world beating productivity.

26 IMD World Talent Ranking 2018


‘Increasingly companies prioritise the availability of skilled local talent when establishing their base of operation.’ National Competitive Council – Ireland’s Competitive Challenges 2018

‘Ireland ranks 20th re higher level education meeting needs of the economy.’ IMD 2019 World Competitiveness Rankings

‘Ireland ranks 21st in a global ranking of countries best able to develop, attract and retain highly skilled workers.’ World Talent Rankings 201826

Recommendations

• Training: Focus National Training Fund/Human Capital Initiative on in-work/enterprise driven programmes.

• Education: Accelerate STEM Action Plan: Promoting STEM careers; teaching CPD rollout and Implement Languages Connect.

• Top Talent: Commit to a stable future-proof funding model for 3rd Level and continued resourcing for Visa-Permits Regime.

Education and Training

Industry and the FDI sector make significant contributors

to higher and further education institutions through the

development of research and innovation programmes,

curriculum development support and work placement

opportunities. Benefits flowing from this engagement

include strengthened learning outcomes, skills alignment

and strategic linkages between industry and the

education and training sector.

The American Chamber is very supportive of the

Action Plans for Education and Ireland’s National Skills

Strategy’s goal of engaging more people in lifelong

learning, as a key approach to boosting firm-level and

national productivity and preparing for a world of work

transforming with the application of digital technology.

The American Chamber recognises that lifelong

learning is a joint enterprise between government and

business; and our member companies are committed to

investing in the training and development needs of their

employees.

The American Chamber welcomed the independent

review of the National Training Fund (NTF) following

the rise in the National Training Levy on employers and

remains of the view that the NTF should pivot its strategic

focus away from labour activation, towards programmes

relevant to employers, delivered with more transparency

and stronger evaluation. The American Chamber is

supportive of the funding for and launch of the Human

Capital Initiative in 2020 in so far as it expedites the

investment on in-work/enterprise driven programmes

to meet the future skills needs of the economy. Our

members remain supportive of alternative pathways

to education (e.g. P-TECH and similar) and career

progression such as the new apprenticeship models and

the reform of Springboard to widen access.

The American Chamber supports the measures

announced in the National Planning Framework and in

the Department of Education’s STEM Education Policy

to boost STEM education; in particular to increase by

20% the total students undertaking Chemistry, Physics,


"Increased funding in targeted education initiatives prepares graduates for the future. Government Education Policy could be better aligned to Ireland’s business needs."

– Site Director, Pharmaceutical Company


22 23

27 See https://www.education.ie/en/Publications/Policy-Reports/Investing-in-National-Ambition-A-Strategy-for -Funding-Higher-Education.pdf

Technology and Engineering at Leaving Certificate level.

However, the American Chamber calls for the increased

funding of STEAM subjects (recognising the contribution

of ‘Arts’ to innovation) and the acceleration of the

implementation of relevant actions arising from the STEM

Education and Review Group, through the provision of

the infrastructure necessary for the digital and language

strategies for schools.

A summary of the American Chamber’s priorities

here includes:

• Advancing the work of the National Skills Council on

future skills foresight, especially as it relates to plans

for the provision of 50,000 upskilling and reskilling

places by 2022.

• Promotion of an Industry-Education collaboration in a

new model for school’s career guidance.

• Continuing to support the ICT Action Plan including

heightened efforts in promoting Ireland as destination

for STEM career opportunities and development.

• Commitment to the STEM Implementation

Programme to include speedy delivery of Computer

Science into the Leaving Cert curriculum, resourcing

the CPD framework for teachers and investment

in promoting STEM careers at all levels within the

education system.

• Bringing forward the implementation of the National

Languages Strategy that supports an all-of-system/

levels approach including in-country immersion for

language development to build on EU programmes

such as Erasmus.

• Delivery on Government’s plan to have 14,000

Apprentice and Traineeships per annum by 2020 by

effective promotion of the opportunities to employer

and candidate markets, encouraging flexibility in

work-training timetables, the use of online tools

and the exploration of headcount cost-sharing

mechanisms to boost provision.

• Building-in performance related metrics to the

funding allocation model for higher level education

with a focus on alignment/engagement with industry

requirements.

• Ensuring there is clear link between the numbers

forecasted to take up work in Ireland and planning for

access to housing and schooling.

The long-term funding of Ireland’s further and third level

sector remains uncertain. Thus, the American Chamber

supports a strategic decision on the recommended

funding options outlined in the report of Expert Group on

Future Funding for Higher Education (July 2016).27

The American Chamber believes that opportunities exist

for further innovation and productivity to contribute to the

sector through proper resourcing, as well as a transparent

and equitable financial participation of the student in their

further education.

Building on the modelling and forecasting from the

Expert Group on Future Skills Needs (EGFSN, and others)

to quantify the demand and supply for specialised talent

under several economic scenarios – the ICT Action Plan’s

strength is its joined-up approach to what is a global

talent challenge. This integrated approach includes: (a)

seeking to generate forecasted skills and competencies

from the pipeline of talent in the education and training

system; (b) activating those already in the workforce to

transition into the ICT sector where demand is located;

and (c) where these measures are forecast to fall short,

and talent from the EU/EEA does not bridge gaps,

having a proactive migration policy by encouraging those

with critical skills to come to Ireland to work and live.

These elements are integral to a systems approach.

The American Chamber continues to support the

resourcing of, and further innovation in, Ireland’s visa

and permits system with the aim of making Ireland’s

regime the international benchmark for forecasted skills

ecosystem needs; leveraging IT and its ease of access

and interaction with users.


Tax Roadmap

"We are constantly in competition with other countries for future investment. Many of our competitors have similar and in some cases more attractive tax regimes."

– General Manager, Manufacturing Site

STEAM subjects - recognising the contribution of ‘Arts’ to innovation

Ireland is a compelling proposition: agile, business-friendly, and known for its certain policy and fiscal environment. We must protect this reputation.


24 25

29 See American Chamber submission ‘ATAD Implementation – Hybrid & Interest Limitation Rules’ https://www.amcham.ie/Advocacy/Policy-Work/Submissions.aspx?page=1

Strengthen Ireland’s Corporate Tax Roadmap

‘Ireland’s corporation tax regime should remain an important part of Ireland’s long-term wider competitiveness offering to support enterprises based in Ireland invest, innovate and compete internationally.’ National Competitive Council – Ireland’s Competitive Challenges

28 See: https://www.gov.ie/en/organisation/department-of-finance/?referrer=/en/updates/irelands-corporation-tax-roadmap

Recommendations

• The importance of the certainty of Ireland’s Regime and its Corporate Tax Rate of 12.5% remains of critical importance.

• EU ATAD Reforms: Consultation is essential on Interest Limitation and Transfer Pricing Rules Changes.

• BEPS 2: Continue to support the Irish Governments position that promotes a multilateral approach to taxation of the digital economy over reactive and economically damaging unilateral measures.

• Double Taxation: In the absence of fundamental reform to its territorial basis remove the ‘Irish measure of income’ limitation for foreign withholding taxes on a formula-based approach and permit the pooling of surplus credits.

Internationally competitive, certain corporate tax policy

is a necessary part of Ireland’s FDI offering to retain and

attract substantive operations in Ireland. The commitment

to Ireland’s regime and its corporate tax rate of 12.5%

must remain. The publication of Ireland’s Corporation

Tax Roadmap28 demonstrates that the Irish tax regime

continues to respond to the changing international

tax competitiveness landscape through ongoing

consultation and open communication with stakeholders.

The American Chamber believes that Ireland should

continue to demonstrate policy development

leadership in multilateral discussions to improve the

efficacy of international taxation rules. In parallel, the

American Chamber welcomes Government’s welcome

commitment to Ireland’s sovereign decision-making

authority, reaffirmation of unanimity at EU level in relation

to taxation matters and its support for international

rules that avoid double taxation, are pro-growth and

employment, and are grounded on value creation.

In respect of discussions on evolving taxation regimes

for a digital economy, the American Chamber strongly

supports the Government’s position to seek a global

solution through the OECD. Government opposition to

the previous EU Commission’s proposed Digital Services

Tax (DST) Directive and Significant Digital Presence (SDP)

Directive should be sustained, to protect innovation

and competitiveness within the European economy.

The American Chamber is most concerned about the

economic damage that taxes on turnover could cause.

Such levies target the turnover of digitalised enterprises

without a link to either profits or the value creation in the

jurisdiction where they are levied.

Certain aspects of the EU’s Anti-Tax Avoidance Directive

(ATAD) were enacted in Irish domestic law from

1 January 2019, with further changes to be enacted

from 1 January 2020 onwards. To improve certainty

the American Chamber would welcome a roadmap of

how the measures will be implemented into Irish tax

legislation, to ensure companies have adequate time to

verify their strategic needs and investment planning for

2020 and beyond with a level of confidence. In addition,

the American Chamber believes a refreshed roadmap

should consider the new EU Mandatory Disclosure Rules

(MDR) as it is essential for Irish resident companies to

understand their obligations in respect of same.

Approach to the recent EU Anti-Tax Avoidance

Directives (ATAD): In prior years, the American Chamber

outlined several recommendations with respect to the

implementation of certain provisions of the ATAD into

Irish law. While certain provisions such as the new CFC

rules and Exit Tax on certain migrations of tax residence

have been introduced into Irish law as of the 2019

and 2018 respectively, there remains the issue of the

implementation of Interest Limitation and Anti Hybrid

rules to be considered on which the American Chamber

has shared its views with the Department of Finance

earlier in 2019.29

In particular, the American Chamber wish to reiterate key

considerations related to the timing of changes to interest

limitation rules under active consideration to include:

• On implementation, the 30% interest limitation should

be included.

• On implementation, the proposed “grandfathering” of

loans entered into pre - 17 June 2016 should

be included.

• The Government should consider how the Interest

limitation provisions can be efficiently implemented

in conjunction with Ireland’s existing tax legislation in

this area. The Chamber believes that simply adding

the proposed interest limitation provisions into

Irish legislation without amending and significantly

simplifying current Irish tax legislation (potentially

on a phased basis) would put Ireland at a significant

competitive disadvantage in this context when

compared to most other Member States.

Transfer Pricing Modernisation: The American Chamber

was pleased to respond to the Department of Finance’s

recent stakeholder consultation on its ambition to


Tax Roadmap

Internationally competitive, certain corporate tax policy is a necessary part of Ireland’s FDI offering to retain and attract substantive operations in Ireland. The 12.5% rate remains of critical importance.


26 27

amend Irish transfer pricing legislation to include a

direct reference to the 2017 OECD Transfer Pricing

Guidelines.30 In supporting changes, the American

Chamber expressed its view that these updates

introduce new concepts and principles which Irish based

business would not have had to consider under the 2010

Guidelines. Hence it is imperative that enough time is

allowed for business to assess the impact on project and

budget planning supported by updated guidance on its

accounting introduction, interpretation of new concepts

and entitlement to intangible related returns, and the

handling of some categories of financing and treasury

transactions still being examined under the OECD BEPS

process. Further, the American Chamber is concerned

that the 2017 Guidelines would be adopted into Irish law,

only then for additional changes to be adopted in short

course, following completion of the current OECD project

relating to the Digital Economy. As the potential output

from this project may result in additional significant tax

reforms/transfer pricing changes, it will be critical for any

further changes to the transfer pricing guidelines that

may arise are implemented on a collaborative basis with

adequate time for companies in Ireland to prepare.

Dispute Resolution: The membership of the American

Chamber is seeing an increase in tax authority scrutiny

and audits internationally which is resulting in the need

for intervention by the Irish Competent Authority to deal

with potential incidents of double taxation. It is critical that

the Irish Competent Authority continues to be adequately

resourced in terms of experienced transfer pricing

professionals and continued training to deal with the

proliferation of mutual agreement procedure (MAP) cases

which are presented. In many cases, the counterparty

tax authorities deal with international transfer pricing

disputes more frequently, which is understandable as

many jurisdictions have transfer pricing regimes for many

years before Ireland introduced a domestic regime in

2011. It is critical that the Irish Competent Authority has

the relevant resources to meet challenges and seek to

protect the domestic tax base.

Double Taxation/Withholding Tax Regime (WHT): It is

important that Ireland can offer a competitive regime

for dealing with withholding taxes suffered on inbound

royalty payments to ensure that Ireland can compete

internationally and be a hub for highly mobile, IP rich

global operations. While Ireland has implemented

various measures to compete for international business,

feedback from American Chamber members confirm

that the current foreign tax credit regime for inbound

royalties remains uncompetitive compared with other

jurisdictions. The Irish Measure of Income regime is now

extremely complex and burdensome for companies, and

despite efforts to simplify it, the opposite is in fact the

case for a lot of taxpayers. The American Chamber is of

the view that in the absence of fundamental reform to its

territorial basis, an enhancement would be to remove the

‘Irish measure of income’ limitation for foreign withholding

taxes on a formula-based approach and permit the

pooling of surplus credits. The American Chamber would

welcome continued stakeholder engagement on this and

related matters of Ireland’s Corporate Tax Roadmap with

the Department of Finance in further detail.

Trade promotion and strategic resourcing will help Ireland remain attractive to FDI.

"There is room to explore greater opportunities for formal engagement between government, industry and business stakeholders to identify issues and agree solutions."

– CEO Global Shared Services Company



30 See American Chamber submission ‘Ireland’s Transfer Pricing Rules Public Consultation’ https://www.amcham.ie/Advocacy/Policy-Work/Submissions.aspx?page=1


28 29

Trade Promotion and World Class Competent Authority Investment

‘The greatest risks to the economy are the UK’s scheduled departure from the European Union (Brexit) in March 2019, possible changes to international taxation policies that could affect Ireland’s revenues, and global trade pressures.’ Ireland ranked 11th on the Forbes Best Countries for Business' list31

31 See https://www.forbes.com/places/ireland/ 32 See ‘The Strongest Link in the Chain’ https://www.amcham.ie/news/publications.aspx

Recommendations

• Trade Promotion: Invest in ‘Ireland’s Global Footprint’ including Enterprise Promotion Agencies in the US market, Export Controls and Trade Facilitation.

• Strategic Resourcing: Data Protection Commission, National Cyber Security Centre and Visa-Permits Regime,

• Continue to invest in Revenue and the Department of Finance to sustain engagement with Ireland’s treaty partner jurisdictions in a timely and authoritative manner.

The American Chamber’s priority is that Ireland remains

a unique transatlantic trade and investment gateway and

a location of choice for US inward investment to Europe.

Inward investment to Ireland continues to make a positive

contribution to Ireland’s economic and social progress.

The competition for investment internationally is intense

as international investment flows react to changing

trade policy and political uncertainty globally, including

Brexit. Jurisdictions are responding by continuously

improving their offering to inward investment; focusing

on attracting talent, investing in physical and digital

infrastructure, encouraging innovation and enhancing tax

competitiveness.

To strengthen Ireland’s capacity to retain and attract

investment and employment into Ireland, the American

Chamber is supportive of continued investment in the

trade and investment arms of the State, including the

marketing and account management leadership of the

Industrial Development Authority and Enterprise Ireland,

the regulatory and supervisory role of the Central Bank

of Ireland in an expanding International Financial Services

and Fintech sector, and the trade development and

economic diplomacy work of the Department of Foreign

Affairs and Trade through its Embassy in Washington D.C.

and its Consulates across the USA.

The Government’s ‘Global Footprint to 2025’ strategy

seeking to strengthening Ireland’s presence in the United

States, including a new diplomatic, trade, business

and cultural promotion hub in Los Angeles and an

enterprise agency presence in Seattle, and investment

in communications to increase visibility, raise awareness

and enhance Ireland’s reputation, is strongly supported

by the American Chamber.

Protecting Ireland’s digital leadership reputation also

requires investment in the key competent authorities

on which Ireland’s digital economy depends. Recent

funding allocations to the Office of the Data Protection

Commissioner has been warmly welcome. The

combination of expanded regulatory responsibility with

the General Data Protection Regulation in force, and

the sustained attractiveness of Ireland for new business

operations in Europe means that this investment

has been necessary. To keep a step ahead of these

twin expansions the Chamber strongly recommends

continued and elevated investment prioritisation for the

new Data Protection Commission.

In a comparable way, the implementation of the

Network and Information Systems (NIS) Directive and

the continuing significance of security and protection

online requires an increase in funding and resources

to the National Cyber Security Centre as outlined in

the American Chamber’s submission to the public

consultation on Ireland’s next National Cyber Security

Strategy.32 Complementary to this focus, the American

Chamber encourages sustained investment in Ireland’s

Export Licencing Unit operating from the Department

of Business, Enterprise and Innovation in their role in

facilitating trade of complex and internationally

controlled technologies.

As previously stated, the American Chamber is strongly of

the view that Revenue, as the Irish Competent Authority

for taxation, continues to be adequately resourced to deal

with increased tax administration and disputer resolution

that will inevitably arise as a result of greater complexity of

taxation allocation rules and conflicting interpretations as

to jurisdictional taxation rights.



The American Chamber’s priority is that Ireland remains a unique transatlantic trade and investment gateway and a location of choice for US inward investment to Europe.


30 31

KEY STATISTICS KEY STATISTICS

US Investment in Ireland Irish Investment in the US

700+ US Companies

in Ireland

800 Irish companies are active in the

US market

325,000 US jobs attributable

to goods and services destined for Ireland

from the US

$ 446 bn US Total Investment

Stock in Ireland $ 116 bn US affiliate sales

generated by Ireland’s investment in the US

100,000+ people employed by Irish

companies in the US

A Transatlantic Hub

Ireland is the gateway to a population of 500

million people

12.6% of all US Investment in the EU is based in

Ireland

100,000 Indirect Employees

supported by US companies in Ireland

155,000 Direct Employees of US

Companies in Ireland

@americanchamber | #USIRL19

The Membership of the American Chamber of Commerce Ireland (AmCham) are the Irish operations of US companies, Irish companies with operations in the United States and organisations with close linkages to US-Ireland trade and investment.

Our members are global leaders in key industry sectors from life sciences to social media. They range from the world’s largest ICT companies who have been present in Ireland for many decades, to operations engaged in life sciences, engineering and internationally traded services, to emerging global leaders in cyber-security who have recently established here.

For more information on membership please contact: Ciara Rushe at [email protected]

“The Republic’s most influential business lobby group.” The Irish Times

“As the voice of US Business in Ireland, AmCham does a fantastic job in bringing US business and Government closer together.”

Heather Humphreys TD, Minister for Business, Enterprise & Innovation

“The American Chamber does a fantastic job in bringing together the broad family of the US FDI community in Ireland, identifying common areas of interest, articulating a position and getting direct access to key policy makers.”

Peter Keegan, Country Executive Ireland at Bank of America Merrill Lynch

About the American Chamber(AmCham Ireland)

OUR MISSION is to strengthen

Ireland’s Transatlantic Business

Relationships through advocacy

& networking with purpose.

NETWORKING WITH PURPOSE Networking at all levels is done through membership networks, programmes and shared best practice events. These networks support deep collaboration and peer-to-peer learning.

ADVOCACY WITH PURPOSE Joining the Chamber gives companies a powerful voice as part of what is recognised as one of the most influential business groups in the country.

BUSINESS GROWTHThe Chamber runs a high-quality event programme covering a range of subjects.

April 2019 Speaker of the United States House of Representatives Nancy Pelosi

addressing AmCham Members

Former Speaker of the House of Representatives John Boehner

addressing AmCham members on Independence Day 2015

OUR VISION Ireland is an inclusive

location-of-choice for talent and

innovation with global impact

pre-budget 2020 · 2019-11-15 · delivering workplace agility, ... reports11 with an enterprise...

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