International Financial Services Centre

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Famine Memorial and IFSC House (IFSC, Custom Quay, East Wall)
Bord Gais Energy Theatre and HSBC HQ (IFSC, Grand Canal Sq.)
Central Bank of Ireland HQ (IFSC, North Wall Quay)
Convention Centre and PwC HQ (IFSC, Spencer Dock, North Wall)

The International Financial Services Centre (or IFSC) began in 1987 as a special economic zone on a derelict 11 hectare site near the centre of Dublin, with EU approval to apply a 10% corporate tax rate for designated financial services activities on the site.[1] Before the expiry of this EU approval in 2005, the Irish Government legislated in 1998/99 to effectively "turn the entire country into an IFSC" by reducing the overall Irish corporate tax rate from 32% to 12.5% (full effect by 2003).[2] The legal requirement for a specific IFSC geographic area was thus removed, and the term International Financial Services ("IFS") sector is now sometimes used.

The original 11 hectare IFSC site has gone through major expansions to become a 37.8 hectare site which is now a major European financial centre and situated within Dublin's central business district.[3] It covers the office areas on the North Wall and East Wall (both north of the river Liffey), and the most recent Dublin City Council ("DCC") 2015 expansion includes the full North Lotts area (down to the Point Depot) and Grand Canal Basin (south of the Liffey) area which includes the Silicon Docks technology zone (home of Google and Facebook in Ireland). The IFSC is migrating into an "international services centre" (or "ISC"), then being purely "financial".[4]

The transition from the IFSC to an "ISC" is logical. The IFSC law and accounting firms created the tax structures US technology firms are famous for using in Ireland (e.g. double Irish, single malt etc.).[5][6] Some of these IFSC law firms also act as registered Irish offices for many types of US multinational tax structures.[7] Also, IFSC law and accounting firms work closely together in creating artificial IP ideas, in offshore locations, that US multinationals of all types (not just financials), can then onshore in Ireland under the capital allowances for intangible assets scheme, and achieve Irish effective tax rates (ETRs) of 0-3%.[8]

An 2015 Irish Government IFS 2020 Strategy Paper[9] lists the IFS sector as comprising over 400 companies, employing over 35,000 people (one third outside Dublin), with over €3.2trn in funds under administration, providing €2bn in taxes and €2.3bn in wages and salaries. KMPG estimate the IFSC constitutes 7% of Irish GDP. [10]

A major 2017 study published in Nature[11] lists the IFSC as one of 5 global conduit OFCs (offshore financial centre) that employ advanced structuring (i.e. double Irish, single malt, capital allowances for intangible assets and section 110 spvs) to legally route funds to 24 global sink OFCs (the main offshore tax havens). It coincides with Ireland's 2016 leprechaun economics moment (and concern on the level of distortion that IFSC activities were having on Irish GDP, GNP and even GNI), and growing reputation as a corporate tax haven/offshore financial centre[12][13][14][15][16] and potentially unregulated[17][18][19] shadow banking centre.[20][21][22][23]

Dublin (via IFSC) ranks 37th of 45 financial centres in the 2014 Xinhua-Dow Jones International Financial Centers Development Index,[24] and ranks 31st (March 2018) on the Global Financial Centres Index (GFCI23) (highest rank was 10th in March 2009 in GFCI5).

Location[edit]

The 11 hectare IFSC I completed site (centre), and the 4.8 hectare IFSC II completed site (right)
IFSC II 4.8-hectare expansion site under construction (January 1998)

The original IFSC I (development of the 11 hectare site from 1987 to 1997 under the Custom House Docks Development Authority "CHDDA") comprises the area between Memorial Road, Amiens Street, Lower Sheriff Street (including part of Crinan Strand), Guild Street, and the River Liffey along North Wall Quay and Custom House Quay. Adjacent districts include East Wall to the north and Spencer Dock to the east; the Custom House, Busáras and the city centre lie to the west along Store Street and Abbey Street. Within the IFSC, the original development area lies west of Commons Street.[25]

East of Commons Street is the later IFSC II (development of an additional 4.8 hectares from 1997 to 2007 under the Dublin Docklands Development Authority "DDDA) which runs along North Wall Quay and Lower Mayor Street. It is an integrated development located in the centre of the city which incorporates office accommodation, educational institutions, housing, restaurants and shopping facilities.[25]

East of Guild Street down as far as the Point Depot is the most recent IFSC III (Docklands Strategic Development Zone, created by Dublin City Council ("DCC") on the dissolution of the DDDA in 2012) into an area containing the Central Bank of Ireland as well the offices of PwC and numerous technology companies including Yahoo. This has was further expanded by DCC in 2015 into a larger special economic zone ("SEZ") to include the full 22 hectares North Lotts and Grand Canal Docks sites. This will comprise both financial (i.e. State Street) and technology services (i.e. Google) companies.[4][26]

Financial sectors[edit]

The main sectors of financial services activity in the IFSC are outlined below:

Fund Administration & Domiciling[edit]

The original proposal for the IFSC was that it would become a location for high-margin investment management and securities trading activity given the low tax rate and proximity to the major centres of London and Paris. For various reasons, the IFSC attracted few such operations with Pioneer Investments being the only real example. Whenever material employment is listed for investment management in the IFSC it is either from domestic Irish fund management firms (i.e. Irish Life Assurance plc) or misclassified IFSC fund administration business.

Classic Fund Administration (i.e. fund accounting, fund administration, fund custody and transfer agency) is the largest employer in IFSC making up almost a third of IFSC jobs and totalling almost 9,274 jobs at the last reliable study.[27] The four largest global fund administration and custody providers all have major offices in the IFSC State Street, Bank of New York Mellon, Citibank and Northern Trust, as well as internal fund administration departments from major global investment banks such as JPMorgan, Goldman Sachs and Bank of America.

These fund administrators compromise the bulk of the large standalone multi-national offices in the IFSC (outside of the multi-national technology firms). The remaining large offices are for domestic Irish legal firms (A&L Goodbody, McCann Fitzgerald, William Fry, Matheson) and accounting firms (PwC) supporting the IFS sector. [28]

Fund Domiciling (and Distribution) is where specialist law firms, and specialist administration departments of investment firms (i.e. Blackrock, Citibank, Deutsche Bank), provide legal (i.e. creating fund prospectus, fund listing documents etc.) and other professional services (i.e. fund trustees, fund audit etc.) to Irish domiciled, and often Irish listed, fund structures in various Irish legal fund "wrappers" (incl. UCITs, QIAIFs, MMFs and AIFs).[29] The IFSC is one of the largest and fastest growing locations for UCITS in Europe.[30]

The trade body for the IFSC Fund Administration and Domiciling sector is the Irish Funds (Industry) Association (previously Dublin Funds Industry Association, or "DIMA").

Securitisation[edit]

The introduction of the Irish Section 110 SPV in 1997, described by PriceWaterhouseCoopers as the "heart of the Irish structured finance regime",[31] enabled the IFSC become the largest provider of SPVs in the EU securitisation market,[32] and has made Ireland the 4th largest shadow banking centre in the world.[33] While Irish securitisation SPVs pay no effective Irish corporate taxes (SPVs are deliberately structured in this way), they are estimated to contribute over €100m annually to the Irish Economy from fees paid to local Irish professional services firms (mainly legal, but also accounting and corporate services providers) who create and administer the SPVs. [34] The sector was involved in a major domestic tax scandal in 2017 (see vulture fund tax avoidance)[35][36]

Note that sometimes the Securitisation Sector is merged with the Fund Administration Sector when "total funds administered" data is quoted for the IFSC (or IFS sector).

The trade body for the IFSC Securitisation sector is the Irish Debt Securities Association (IDSA).

Banking & Insurance[edit]

Some of the world's largest banks have offices in the IFSC. Their focus is mainly on administration support for securitisation and structured finance activities, aircraft leasing activities, or conducting in-house corporate treasury and fund administration functions for their parent. There are no examples yet of foreign banks conducting higher margin investment Banking, securities trading or corporate banking or corporate finance from their IFSC platform (instead favouring their bases in London, Paris or Frankfurt in Europe).[37]

The trade body for the IFSC and non-IFSC Banking Sector is the Irish Banking and Payments Federation Ireland (BPFI)

The main insurance activities cover Life Insurance (mostly niche investment products from niche firms), General Insurance (also niche risk products from niche firms), Reinsurance (Solvency II consolidation wrappers from major offshore players) and Captive Insurance (in-house self-insurers of major multi-nationals). There is little insurance risk originated or underwritten in the IFSC (London is the base for such activities), however, the IFSC provides an administration platform and legal / taxation wrappers for niche insurance products sold on a pan-EU basis through the parent's main channels. The IFSC has a particular strength as a top location in the Captive Insurance market.[38][37]

The trade body for the IFSC Insurance sector is the Dublin International Insurance & Management Association (DIMA).

Aircraft leasing[edit]

The IFSC is one of the largest aircraft leasing hubs in the world with 14 of the top 15 aircraft lessors headquartered in Ireland (including Aercap, GECAS, RBS, SMBC and Avalon) and circa 50% of the world’s fleet of leased aircraft is managed through IFSC companies.[39][40] Unlike most other IFSC sectors, the Aircraft Leasing sector includes high margin activities (including origination and financing). While the sector employs under 1,000 people (versus Fund Administration at almost 10,000 jobs), and pays less than €40m in Irish corporate tax[41] it is estimated to provide over €500m annually to the Irish Economy (from salaries and fees)[42] making it one of the most valuable sectors in the IFSC.

The closest related trade body for the IFSC Aircraft Leasing sector is the Irish Aviation Authority (IAA) (not exclusively IFSC focused).

Corporate Treasury[edit]

The Corporate Treasury sector primarily consists of small IFSC subsidiaries of large non-financial multi-national services organisations (e.g. Pfizer, Xerox), which serve as a hub for in-house treasury functions (i.e. cash pooling, fx hedging), for their global parent and sometimes serving as shared services centres serving multiple locations and functions (providing administration and bookkeeping functions). While it is roughly estimated that between only 200-300 people are directly employed in the Corporate Treasury sector, the level of Irish corporation tax paid by these hubs is close to €200m per annum,[37] making it more valuable to the Irish Economy then the higher profile IFSC Securitisation sector. It is likely that some of this are from the significant treasury activities of the US Technology firms (Google, Apple, Facebook and Amazon) who have large offices in the IFSC.

The closest related trade body for the IFSC Corporate Treasury sector is the Irish Association of Corporate Treasurers (IACT) (not exclusively IFSC focused).

Payments processing[edit]

This is a more diverse sector that covers classic payments companies (US credit card processing companies like VISA and Mastercard), internet and Fintech payments companies (i.e. PayPal, Stripe), and other niche payment processors (i.e. FEXCO, Taxback, Realex Payments). The attraction is Ireland's beneficial tax regime for contract manufacturing (previously developed for the pharmaceutical sector in Ireland) which makes Ireland a low / zero tax centre for handling payments.

The closest trade body for the IFSC Payments sector is the Fintech Payments Association of Ireland (FPAI) (not exclusively IFSC focused).

Fintech[edit]

Payments aside, some Irish reports note Fintech as a growth sector in the IFSC and list some domestic technology firms active in the Fintech space. There are also often some established global financial names listed alongside as conducting "technology incubators" for Fintech development in the IFSC.

These situations should be taken with the caveat that the 2009 Finance Act Capital Allowances for Intangible Assets tax scheme enables multi-nationals to reduce their Irish taxable profits (i.e. from providing Fund Administration services) where Group intellectual property (IP) purchased by the Irish subsidiary (with inter-group loans), and the acquisition costs written off over 5-15 years against Irish tax. The rules require a level of "work" to be done by Irish employees on this IP, however, the tax is the driver of the "work", not Fintech.

The expanded capital allowances arrangement was set up as a replacement for the double Irish scheme used by US technology multi-nationals in Ireland.

Technology expansion[edit]

The IFSC III phase has seen the "financial" IFSC effectively merge with the Silicon Docks technology area, comprising major offices of Google, Facebook, and Amazon. These US technology firms use well publicised Irish IP-based BEPS tools, or "multinational tax schemes" (such as the double Irish), to shield non-US global profits from the US "worldwide taxation" system (with few exceptions, non-US multi-nationals usually don't need to use Ireland, as their own home country will usually have a "territorial tax" system allowing much lower rates of tax on foreign sourced income).[43]

This is a logical expansion given that the same IFSC Irish law firms (i.e. Matheson, A&L Goodbody, McCann Fitzgerald, William Fry etc.) and IFSC accounting firms (i.e. PWC), advise both the major financial multinationals and the major technology multinationals, operating in the expanded IFSC III zone. It was PwC who created the double Irish,[5][6] while several US technology firms use the Section 110 SPV structure which IFSC law firms created for the IFSC Securitisation Sector (above). Some of these IFSC law firms also act as registered Irish offices for many types of US multinational tax structures.[7]

Also, with the end of the double Irish scheme in 2020, Ireland's economy is very reliant on the capital allowances for intangible assets BEPS tool being able to replace it, and continue to give multinationals effective tax rates (ETRs) in Ireland of 0-3%.[44] The capital allowances for intangible assets scheme relies on multinationals being able to create artificial internal group IP, in offshore locations, which can then be purchased, via intergroup loans, by an Irish subsidiary. The only real hurdle is to have an accounting firm validate the IP in the annual accounts (which can be old 2004 Irish GAAP).[45][46]

In this regard, the IFSC accounting and legal firms will be instrumental in working closely together advising multinationals (not just financials), on how to:[47][8]

Of the wider tax environment, O’Rourke thinks the OECD base-erosion and profit-shifting (BEPS) process is “very good” for Ireland. “If BEPS sees itself to a conclusion, it will be good for Ireland.”

Feargal O'Rourke CEO PwC (Ireland)
"Architect" of the double Irish[5][6]
Irish Times, 2015[48]

  • Create and develop IP ideas in offshore locations (purchase some cheap source-IP from U.S. parent);
  • Place a high valuation on this offshore IP;
  • Bring the IP onshore to Ireland via an "arms-length" acquisition (OECD-compliant);
  • Secure Revenue Commissioners approval to amortise the IP under the capital allowances for intangible assets scheme (for 0-3% Irish ETRs);
  • Conduct the annual GAAP audit of the onshored IP assets under Irish GAAP;
  • Maintain the cycle of creation so that new IP can be purchased when the old IP is fully amortised (using the corporate's "product cycles").

"It is hard to imagine any business, under the current [Irish] IP regime, which could not generate substantial intangible assets under Irish GAAP that would be eligible for relief under [the Irish] capital allowances [for intangible assets scheme]." "This puts the attractive 2.5% Irish IP-tax rate within reach of almost any global business that relocates to Ireland."

— KPMG, "Intellectual Property Tax", 4 December 2017[49]

The scale of tax sheltering by US technology multinationals in Ireland has been shown by offshore financial centre expert Gabriel Zucman to be largest in Europe.[50]

The US Tax Cuts and Jobs Act of 2017 switch to a "territorial tax" system[51][52][53] may affect the IFSC's attraction to US technology firms in particular.[54] Parts of the US TCJA are focused on Irish "multinational tax schemes" above.[54][55] The TCJA's FDII rate, gives US multinationals an "Irish type" low tax rate (13.125%) for their royalty schemes created from US based intellectual property. The TCJA GILTI rate, ensures that Irish "multinational tax schemes" (with effective Irish corporate tax rates of 0-3%), will produce effective tax rates above the FDII rate, for US multinationals in their US tax return.[56]

The EU's Digital Services Tax is seen as directed at Irish "multinational tax schemes" as mostly used by US technology firms.[57][58] As with the US TCJA GILTI rate, the EU "digital tax" is designed to "override" Ireland's tax structures and force a minimum level of EU tax on US technology firms. The EU's Common Consolidated Corporate Tax Base ("CCCTB"), would even more severely affect the IFSC.[59][60]

Corporate tax haven[edit]

Uncovering Offshore Financial Centers: Network of ownership connections between countries

The IFSC's growth has led to Ireland's rise in global league tables of corporate tax havens[12][13][61][14] and seen Ireland "black listed" by countries such as Brazil.[15][16]

There is evidence IFSC SPVs are being used for circumvention of sanctions,[20] tax avoidance,[21][62][63][64][65][66] and money laundering.[67][23][68][19][22]

Research by Trinity College Dublin Professor Jim Stewart and Cillian Doyle shows many IFSC SPVs (or financial controlled vehicles, FCVs) are effectively unregulated brass plate type structures attracting little oversight by the Revenue Commissioners or Central Bank of Ireland, and with local individuals holding hundreds of SPV directorships.[69][70] The International Monetary Fund ("IMF") has noted the same concern regarding governance of IFSC SPVs (and FCVs).[17]

The former Deputy Governor of the Central Bank of Ireland said that IFSC SPV abuse is not fully appreciated by the Irish Government.[18]

Respected Irish financial commentators are concerned of the impact on Ireland's reputation (and effect on the key Irish US multinational technology sector).[71][72]

In contrast, the Irish Government, and many respected Irish and International financial commentators, counter that Ireland (and the IFSC) operates in a fully transparent legal and regulatory system that is well regarded by both the EU and the OECD.[73][74][75][76]

A major report published in Nature in 2017 on the analysis of offshore financial centres "Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network" [11] explains the disconnect between these two sets of contrasting views.

The report examined global company ownership connections to identify 5 global conduit OFCs (Netherlands, United Kingdom, Ireland, Singapore and Switzerland). These are countries of high financial reputation (i.e. not formally labelled "tax havens"), but who have "advanced" legal and tax structuring vehicles (and SPVs) that can legally route funds to the 24 tax havens (called sink OFCs), without incurring tax in the conduit OFC (or even tax in the source of funds location, where royalty payment schemes like the double irish or single malt can be used).[11]

Conduit OFCs tend to be dominated by large specialist law firms (and offshore magic circle law firms from Sink OFCs) and global accounting firms, who create the lawfully constructed vehicles that make the sink OFC connections, by exploiting legislative loopholes. They advise clients on anticipating future changes (i.e. from slow moving OECD BEPS processes) that may need new loopholes.[77]

In conduit OFCs (or corporate tax havens), these law and accounting firms lobby heavily/write most of, the State's relevant SPV legislation (where they create the new loopholes).[11][78][79]

The largest IFSC offices are now law firms (including sink OFC specialists [80][81]) and global accounting firms, whose financial structuring have reached global attention:

  • PwC, whose Managing Partner is regarded by Bloomberg as the "great architect" of the double Irish, the largest known legal tax avoidance structure in history.[5][48][6][82]
  • Matheson, which the Wall Street Journal discovered was the headquarters of 125 major US multi-nationals seeking to benefit from the Irish tax system.[7]

When it was found that US distressed debt funds were using IFSC Section 110 SPVs to avoid potenaitlly billions in Irish taxes on their Irish investments[83] (see vulture fund Irish tax avoidance), supported by IFSC law and accounting firms,[84][85] it was reported as a consequence of having an IFSC SPV sector.[86] These tax losses may exceed the entire cumulative value of the IFSC SPV sector.[87]

Other activities[edit]

The National College of Ireland is situated within the IFSC area (providing training and employment support).

The new Central Bank of Ireland headquarters building is also situated here (the regulator of the IFSC).

Finally, the new National Convention Centre is also located in the heart of the IFSC (just off the new Samuel Beckett Bridge).

History[edit]

The concept of a low tax "international financial service centre" is generally attributed to Irish businessman Dermot Desmond, whose idea was picked up by Fianna Fail leader Charles Haughey and incorporated into his 1987 election manifesto (with contributions from AIB CEO Michael Buckley). Despite resistance from the Department of Finance (concerned about the impact on domestic tax revenues), Haughey overruled and got permission from the EU to create a special 10% tax incentive zone (the IFSC), in the 1987 Finance Act (Section 30).[88]

The physical manifestation of the IFSC began with the construction of three major offices (The International Centre, IFSC House and La Touche House) which today still carry a distinctive "green" colouring. To operate in the IFSC (and access the 10% tax rate) companies had to be approved by the Certification Advisory Committee (CAC), composed of representatives from the Irish Development Authority, the Department of Finance, the Department of Enterprise and Employment and the Central Bank of Ireland.[89]

The next major event was the Irish Taxes and Consolidated Act, 1997 ("TCA") which upgraded the legal and tax structures available in the IFSC, and in particular created the new " Irish section 110 SPV" and laid the foundations for the double Irish, single malt and the capital allowances for intangible assets taxation arrangements. In addition, the Dublin Docklands Development Authority was set up to oversee the expansion of the IFSC's site (most notable being the reclamation of the Grand Canal Basin site)[90]

The "dual structure" Irish corporate tax rate, came under pressure from the EC (due to Competition Rules), and it was agreed that it would expire in 2005. In advance of this deadline, the Irish Government in the 1998/1999 Finance Acts introduced a lower 12.5% corporate tax rate for the entire country which was fully introduced from 1st January 2003, and by 1st January 2006, all remaining IFSC companies (some held their old licenses) were on a 12.5% rate. The IFSC ceased to exist as a required legal entity.[1][2]

The next major event was the Irish financial crisis from 2008-2013. The IFSC was a major EU securitisation hub and the effect of billion euro special purpose vehicles (or SPVs) collapsing[91] added to the concern over Ireland's financial position. It did not help that these SPVs (and other IFSC type activities) produced a further distorted picture of Ireland's already precarious National Accounts statistics.[92] The sudden drop in Dublin's ranking on the Global Financial Centres Index ("GFCI") from an all-time high of 10th in March 2009 (GFCI 5), to 23rd by September 2009 (GFCI 6), sparked a formal investigation.[93]

A tightening by the Irish regulator (after a period of lose regulation) which followed the Irish financial crisis led some financial institutions to move operations elsewhere (as well as others who were exited)[94] and caused Dublin's GFCI ranking as a financial services centre to drop further to 70th in 2014 (GFI 16).[95] IFSC institutions cited the timeliness of decisions by the Central Bank of Ireland as having an impact on their operations.[96] Since 2014 however, the IFSC has started to recover, rising to 31 in the 2016 GCFI 21 ranking.[97]

The IFSC Securitisation Sector produced a major domestic scandal when it was revealed in mid 2016 that US Distressed Debt funds (pejoratively called "vulture funds") had been using the Irish Section 110 SPV to avoid all Irish taxes on their Irish domestic investments. The Irish Government closed the "loopholes" but it was estimated that the loss in Irish tax revenues to the Irish exchequer runs to billions of euros (exceeding the value the securitisation sector ever delivered to Ireland). Discussed further in vulture fund Irish tax avoidance.

The IFSC Securitisation Sector was further pressured when it was revealed in 2018 that Russian Banks (some under EU and US sanctions) had also been using the Irish Section 110 SPV to funnel over €100bn through the IFSC. Further academic studies showed that the IFSC SPV sector was operating in an almost unregulated fashion where structures were more akin to brass plate companies. Other ex. Central Bank of Ireland regulators also publicly highlighted their concerns. Discussed further in unregulated shadow banking.

The current focus for the IFSC is around the potential gains from Brexit but it is too early to tell how this will play out. It has become clear however that IFSC's existing traditional weakness in not attracting higher-margin fund management, banking or insurance activities remains an issue with Frankfurt and Paris (banking and fund management) and Luxembourg (insurance) being the early winners of Brexit re-locations.[98] However, the IFSC's position as the last common law centre in the EU could support its Securitisation Sector.[99]

Major IFSC offices[edit]

Fund Administration

Banking & Insurance

Aircraft Leasing

Payments Processing

Trading

Fintech and Regtech

Managed Futures

See also[edit]

References[edit]

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External links[edit]

Coordinates: 53°20′58.28″N 6°14′49.97″W / 53.3495222°N 6.2472139°W / 53.3495222; -6.2472139