Insights Life Sciences

EU Continues to Progress with HOT Proposal

A proposal for the taxation of cross-border branches known as “the head office tax” or “HOT” system is currently making its way through the EU…

20/05/24

About Niamh

Niamh is a Partner and Co-Head of our Tax team who advises Irish and international clients on tax law and tax planning in the context of mergers and acquisitions, restructurings, joint ventures and investments. She has extensive experience spanning several sectors including financial services, technology, life sciences, energy and real estate. Clients know Niamh for her concise and practical legal advice.

Niamh has a particular focus on advising financial institutions, lenders, assets managers and investors on tax matters relevant to financing and financial services tax. This includes advising on Irish withholding tax on interest, double tax treaty relief, availing of the 12.5% trading rate and availing of the special tax regime for investment funds and structured finance / securitisation transactions.

Related Practice Areas

Specialties

Tax structuring of M&A deals including cross-border transactions
Financial Services tax
Real estate tax
Transactional taxes e.g. capital gains tax, stamp duty
International tax and tax treaty interpretation issues, multi-nationals international investors, financial institutions, asset managers

Additional Information

Engagements

Niamh is involved in many industry initiatives and currently sits on the following representative bodies:

Tax Committee of the Law Society of Ireland
Tax Committee of the Irish Debt Securities Association (IDSA)
Irish Funds Industry Tax Working Groups
Irish Revenue Advisory Body: TALC BEPS & DAC 7 Committees

Education

University College Dublin , BCL
The Honourable Society of Kings Inns , BL
Irish Tax Institute, Chartered Tax Advisor
Solicitor, Law Society of Ireland

Professional Memberships

International Fiscal Association
American Bar Association
Law Society of Ireland
Irish Tax Institute

Representative Matters

Advised Biohaven on entering into a collaboration agreement with Pfizer and on the later sale of Biohaven Pharmaceutical Ireland DAC (a commercial stage biopharmaceutical company) to Pfizer
Advised a major European bank on several structured finance transactions in Ireland
Advised market leading US private equity fund in connection with securitisation transactions
Advised EdgeConnex on structuring in the context of the ongoing development of data centres in Ireland
Advised Statkraft on the development and sale of renewable projects in Ireland
Advised Airbus on the tax aspects of structuring and implementing a reorganisation

Niamh Caffrey

EU Continues to Progress with HOT Proposal

About Niamh

Engagements

Education

Professional Memberships

Assessing Built Environment Workers' Status for Tax Purposes

Assessing Technology Workers' Status for Tax Purposes

The European Commission Prevails in its Apple State Aid Action Against Ireland

Assessing Financial Services Workers' Status for Tax Purposes

CPD on Demand: Life Sciences – Legal & Tax Considerations for Ireland