1. SWEDISH CHAMBER OF COMMERCE TAX INCENTIVES FOR BUSINESS GERRY VAHEY 11 April 2013

2. TABLE OF CONTENTS 1.Corporation Tax Rates, Losses, deductions etc 2.Start up Exemption 3.Holding Company – Participation Exemption 4.Research & Development Tax Credit 5.EIIS & Seed Capital Relief 6.Assignment Relief (SARP) 7.Foreign Earnings Deduction (FED) 8.Other Issues 2

3. CORPORATION TAX - GENERAL 12.5%, 25% Tax deduction for most items of expenditure Incorporation versus Sole Trade Intangible Assets 3

4. Overview Relief from Corporation Tax First 3 years Profits Incorporation and Commencement Employment Based Relief START UP EXEMPTION

5. The Relief Relief of up to 40,000 Marginal Relief to 60,000 Trading Profits Carry forward of losses START UP EXEMPTION

6. HOLDING COMPANY – PARTICIPATION EXEMPTION 6 HoldCo Trade Co

7. RESEARCH & DEVELOPMENT TAX CREDIT 25% Tax Credit Offset against Corporation Tax Refunded over 3 years Reward key employees

8. COMPANY TAX CREDIT 60,000 RDTC Year 1 Refund Year 2 Refund Year 3 Refund Year 4 Refund Year 120,000 - Year 2-20,000 Year 3--20,000 Year 4---20,000 40,00060,000

9. DIRECT R&D EXPENDITURE Direct Staff CostsRaw MaterialsDirect Over-heads Computer Software & Hardware costs Sub Contracted R&D Costs (Rules) Plant & Machinery Buildings (Special Improved Rules Apply) Fixtures & Fittings Other ?

10. SOME….QUALIFYING ACTIVITIES prototyping design trials testing moulding workings drawings failed attempts recipes blending reaction extensive testing process & output performance Stability control first batch scale up production clinical trials process & output improvements Algorithm & OS development statistical data management generic software improvements Qualifying Activities

11. SOME …. QUALIFYING ACTIVITIES (BROWN COAT?) Process Improvements : Definable Increases in Output, Volume, Running Time etc Automation

12. MONEY BACK FROM REVENUE Reliefs Employment and Investment Incentive Scheme (EIIS) Seed Capital Relief Start-up Relief How these interact with R&D Tax Credit

13. EMPLOYMENT AND INVESTMENT INCENTIVE SCHEME (EIIS)

14. Benefits Cash for Company Income Tax Relief for Investor

15. EMPLOYMENT AND INVESTMENT INCENTIVE SCHEME (EIIS) The Company Trading company Unquoted Residence & Incorporation Micro, Small and some Medium Sized Enterprises Max Lifetime limit of 10m Max Annual limit of 2.5m

16. EMPLOYMENT AND INVESTMENT INCENTIVE SCHEME (EIIS) The Investor Resident in Ireland Hold shares for 3 years Not connected to company Relief of 150,000 in any one year

17. EMPLOYMENT AND INVESTMENT INCENTIVE SCHEME (EIIS) Tax Relief Initially - 30% After 3 years - 11%

18. EMPLOYMENT AND INVESTMENT INCENTIVE SCHEME (EIIS) Practical Issues EIIS Investors EIIS Funds Exit Strategies?

19. SEED CAPITAL RELIEF

20. Key Employment in last 6 years? Paid PAYE on Employment Income? Entitled to Income Tax Refund?!!

21. SEED CAPITAL RELIEF The Relief Refund of Income Tax Max of 100k per annum Previous 6 years

22. SEED CAPITAL RELIEF Conditions Investment in Shares Qualifying Company Creation of Employment Qualifying Employment

23. ASSIGNMENT RELIEF SARP Inbound employees Exempt 30% of income - 75K to 30K Relevant Employee 23

24. FOREIGN EARNINGS DEDUCTION Outbound workers BRICS + Others Max relief is 35K Dependent on number of days 24

25. OTHER ISSUES Double taxation network Ease of administration Expansion abroad Remittance Basis Revenue Audits 25

26. mazars.ie CONTACT Mazars Harcourt Centre Block 3, Harcourt Road Dublin 2, Ireland Tel: +353 (01) 4494400 Email: mazars@mazars.ie Mazars Place, Salthill Galway, Ireland Tel: +353 (091) 583242 Email: mt@mazars.ie