🇮🇪 Ireland
12.5% corporate tax. Section 110 SPV. The EU base for Apple, Google — and you.
Tax
12.5% / near 0% Section 110
Setup from
€18,500
Timeline
10–14 weeks
Ownership
100% foreign
Why Ireland
Key advantages
12.5% corporate tax
Lowest standard rate consistently applied in the EU.
Section 110 SPV
Structure that reduces taxable profit to near zero through interest payments.
US–EU treaty bridge
Most favourable US treaty of any EU member.
IP holding regime
Major deductions available for intellectual property.
Common law
Familiar to US and UK counterparties.
What We Build
Full scope of implementation
- ✓Irish Limited Company or Section 110 SPV
- ✓Substance: registered office, local/EEA director
- ✓Tax registration with Revenue
- ✓Section 110 structure + Profit Participating Note documentation
- ✓Bank account + annual CRO return
Who This Is For
Ideal client profiles
→EU holding companies for groups with US operations
→Investment vehicles and debt management (Section 110)
→IP holding for software and patents
→Businesses needing the EU's strongest US treaty
Our Offer
Ireland as your EU holding headquarters — with the same tools used by Fortune 500 companies.