Download here - Irish Tax Institute

TEAM NAME: TCA & THE 110’S
Lecturer: Miss Kate O’Toole B.L.
FANTYASY
BUDGET 2017
Irish Tax Institute
Member Name’s
Diarmuid Donnellan, Luke Walsh & Robert Segarty
Introduction
There have been various problems that the government has sought to address in this budget
including: high rental rates due to a housing shortages that affect individuals and families; and
the future impact of Brexit on SMEs in Ireland. Finally, the budget has sought to consolidate
economic progress by keeping the corporation tax rate at 12.5% despite global scrutiny.
One Key Measure Affecting the Individual/family
Budget 2017 has sought to address the housing crises in various respects. This is an issue that
has affected individuals and families across the country. It has been widely documented that
there have been housing shortages throughout the country in recent years particularly in
Dublin.1 At the same time, there are vacant houses around the country where the demand for
housing is lower. One of the manifestations of the housing crises is high rents which have hit
a record high after a 10% rise in September 2016.2
1
Kitty Holland, ‘5,000 new homes a year needed to meet social housing demand’, Irish Times (Dublin 26 May
2014) <http://www.independent.ie/business/irish/housing-shortage-just-3000-properties-for-sale-in-dublinat-present-29882239.html>; Sarah McCabe, Housing shortage: Just 3000 properties for sale in Dublin at
present’, the Irish Independent, (Dublin 22 January 2014) <http://www.irishtimes.com/life-and-style/homesand-property/5-000-new-homes-a-year-needed-to-meet-social-housing-demand-1.1808394> accessed 28
October 2016.
2
Conor Pope, ‘Dublin hits record high after 10% rise nationwide’, Irish Times (Dublin, 15 Sep 2016)
<http://www.irishtimes.com/news/environment/dublin-rents-hit-record-high-after-10-rise-nationwide1.2791482> accessed 28 October 2016.
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Source: PRTB Average Monthly Rent Report by Property Type.3
The government announced during the summer that economic recovery had been faster than
expected.4 An increase in demand for houses was likely caused by the improvement in the
economy. Budget 2017 has introduced various measures to combat the lack of housing in urban
areas such as Dublin including; the help to buy scheme, the rent relief scheme and the provision
of 1.2 billion in funding for social housing units which will be available by 2021.5 One measure
that particularly stands out is the increase in tax relief, from 75% to 80%, on interest paid on
loans used to buy or improve rented residential property. This will particularly target the high
rates of rent that families and individuals face in Dublin. The concept behind this measure is to
decrease the expenses faced by landlords and thus increase supply of rental accommodation in
the market. Section 97(2) of the TCA 1997 provides for a deduction in respect of interest on
borrowed money employed in the purchase, improvement or repair of the premises. However,
3
‘Average Monthly Rent Report by Property Type’ (PRTB 2016)
<http://www.cso.ie/px/pxeirestat/statire/SelectVarVal/Define.asp?Maintable=RIA02&PLanguage=0> accessed
28 October 2016.
4
Department of Finance, Summer Economic Statement, (2016) ch 1 economic strategy: outlined the growth of
GDP in 2015 was the strongest since 2000.
5
Budget 2017.
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the law imposes several safeguards on such deductions; s.16 of the Finance Act 2003 provides
that one spouse cannot buy another house and let it to the other spouse. If this restriction was
not in place, unconscionable conduct could occur whereby parties would effectively receive a
subsidy of sorts on their second house. This would defeat the aim of the legislation and the new
measure introduced by budget 2017 which is to encourage people to lease residential property.
The deduction of the interest is conditional on the borrower meeting registration requirements
of the Residential Tenancies Act 2004. Again this is to ensure that those who will stand to
benefit from the increased interest relief are actually meeting a public interest.
Overall, this measure seems to be beneficial as there is a supply deficit in the housing market
and this will incentivise landlords to charge less rent and it may even incentivise more people
to rent houses. However, the interest rate deduction may be too minimal to incentivise enough
landlords into the market. The government has also proposed a help to by scheme which will
facilitate demand for houses.6 This is based on Keynesian economics which holds the view that
shortages in commodities are caused by a lack of demand rather than a lack of supply. As a
result the government is confronting the issues from both demand and supply perspectives.
Measure affecting Small and Medium Sized Enterprises (SMEs)
Small and medium businesses make up 68% of all employment in Ireland as of 2014.7 It is
anticipated that imports and exports from SMEs will be negatively affected by Brexit, but the
budget has implemented measures to assist the Irish economy in becoming “Brexit-proof”.8
One such measure introduced in the recent budget was a decrease in Capital Gains tax to 10%.
This 10% rate only applies to the first €1 million.
6
Jim Clery, Taxing Times: Budget 2017 and Current Developments, (KPMG, 2016)
<https://assets.kpmg.com/content/dam/kpmg/ie/pdf/2016/10/taxing-times-budget-2017-1.pdf> accessed 28
October 2016: the objective of this scheme is to increase demand and with the increased demand supply will
follow.
7
John Kennedy, ‘Budget 2016: Changes to income and capital gains tax for entrepreneurs’ (Siliconrepublic, 13
October 2015) < https://www.siliconrepublic.com/start-ups/budget-2016-changes-to-income-and-capitalgains-tax-for-entrepreneurs> accessed 26 November 2016.
8
Colin Gleeson, ‘The business community has its say on Budget 2017’ The Irish Times (Dublin, 12 October
2016).
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Source: Business Ireland, 2011, Central Statistics Office.9
Interest groups have pushed for a €10 million cap.10 The SFA Chairman, emphasised how our
tax system needs to compete with the UK. Halving CGT was a welcome measure, but there is
clear disappointment that the government has missed the opportunity to attract entrepreneurs,
due to our limit being €9 million lower than that in the UK. 11 Commentators have referred to
the reduction of CGT as ‘peanuts’.12 The standard rate of 33% will apply to anything above €1
million.13 Ireland cannot afford to be less attractive for entrepreneurs than our British
counterparts.
9
Central Statistics Office, Business in Ireland 2011 (Government of Ireland, 2013) 6: statistics have not changed
significantly since 2011.
10
Ciarán Hancock, ‘Budget 2017: the measures designed to soften blow of Brexit’ The Irish Times (Dublin, 12
October 2016).
11
Conor O’Brien, ‘Budget 2017 reaction: KPMG Ireland hails ‘cautious and prudent’ budget’ Irish Examiner
(Cork, 11 October 2016).
12
John Kennedy, ‘Budget 2017: Caulfield says capital gains tax cut is ‘peanuts’’ (Siliconrepublic, 11 October
2016) < https://www.siliconrepublic.com/start-ups/capital-gains-tax-caulfield-budget-2017> accessed 25
October 2016.
13
Paul O’Donoghue, ‘Budget 2017: The budget has failed to deliver for small businesses’ (the journal, 11
October 2016) < http://www.thejournal.ie/capital-gains-tax-budget-shares-2-3021506-Oct2016/> accessed 26
October 2016.
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The reduction in CGT is a commitment by the government to improving the indigenous
business opportunities within the country. A review published in 2013 found that the relief
supported 1,038 companies employing 11,750 people at an estimated cost of €4.9 million.14
The reduction in CGT is also going to result in a revenue loss of €13 million. While there is a
welcome new focus on export-led growth for indigenous competition, this may prove difficult,
as we cannot simply reduce reliance on the UK.15 Around 30% of Ireland’s trade imports are
sourced from the UK alone and on average 16% of Irish exports go to the UK, of which 40%
are exports from indigenous companies.16 This also makes Ireland the UK’s fifth largest export
market.17 Overall, approximately 70% of all material manufacturing by our indigenous
businesses is linked to the UK.
Source: Census of Industrial Production 2012, Department of Finance Analysis.18
14
John Kennedy, ‘Budget 2016: Changes to income and capital gains tax for entrepreneurs’ (Siliconrepublic, 13
October 2015) < https://www.siliconrepublic.com/start-ups/budget-2016-changes-to-income-and-capitalgains-tax-for-entrepreneurs> accessed 26 October 2016.
15
Department of Finance, Getting Ireland Brexit Ready (Government of Ireland, 2016) 4.
16
Department of Finance, Getting Ireland Brexit Ready (Government of Ireland, 2016) 4.
17
Ciarán Hancock, ‘Budget 2017: the measures designed to soften blow of Brexit’ The Irish Times (Dublin, 12
October 2016).
18
Department of Finance, UK EU Exit - An Exposure Analysis of Sectors of the Irish Economy (Government of
Ireland, 2016) 6.
5|Page
The most exposed businesses are SMEs, which have high levels of regional employment but
also have low profit levels. The reduction of the CGT and the increase in income tax credits
will hopefully offset these low profits and also influence investment. In July 2016, ISME
spokesmen called the tax system ‘unfriendly to start-ups and SMEs.’19 They called for equal
tax treatment and stated that the government were hampering firms’ growth. It appears that the
Revenue is trying to minimise the costs on business and maximise facilitation of trade postBrexit. However, there is no denying that despite these measures, indigenous SME’s are facing
an uphill battle.20 Despite, improvements the budget has simply failed to deliver in certain key
areas. Increased assistance to SMEs through the above measures may add extra cost to the
economy, however, by assisting these indigenous businesses they will surely benefit the
economy. Such benefits would be more than capable of lowering the deficit and furthering the
prospects of growth for SMEs.
19
Mark Fielding, ‘Budget 2017 Government Must ‘Think Small First’’ (Irish Small And Medium Enterprise
Association, 20 July 2016) < http://isme.ie/budget-2017-government-must-think-small-first> accessed 26
October 2016.
20
John McSweeney, ‘Challenges facing SMEs in the current climate’ (Institute of Directors in Ireland, 27 April
2015) < https://www.iodireland.ie/news-events/blog/challenges-facing-smes-current-climate> accessed 27
October 2016.
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Source: Census of Industrial Production 2012, Department of Finance Analysis.21
Measure Affecting Foreign Direct Investment
Despite international pressure the Minister has unsurprisingly elected to maintain Ireland’s
competitive 12.5% corporate tax rate on company trading profits. As the saying goes in
Ireland, “we play fair but we play to win”22, this has become an integral part of our economy.
It has also contributed immensely to our strong growth in the post-recession period compared
to other less competitive markets as illustrated below:
21
Department of Finance, UK EU Exit - An Exposure Analysis of Sectors of the Irish Economy (Government of
Ireland, 2016) 6.
22
A. Anderson ‘Investment in Ireland: A success story’ (2014) National Foreign Trade Council.
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Source: Eurostat exert 2011-201523
The final figures for 2015 are somewhat conflated, as a 26% growth in GDP would be “a
work of Irish fiction” however, it is slightly more complicated as the figures are not merely
coincidental, since they illustrate recent moves of certain corporations having moved their
headquarters away from New York to Dublin.24 Such corporations transferred the intellectual
property rights along with the HQ resulting in a large spike on the national balance sheets
which can be largely attributed to the corporation tax rate.25 This is not just for Intellectual
Property which is largely reflective in the charts but also for other vital industries such as
Pharmachem. Both, industries contribute massively to the economy on many levels. First, it
accounts for a large amount of our GDP in terms of exports, secondly they provide a large
amount of direct and indirect employment and finally, they are contributing an increasingly
large amount in terms of corporate tax now standing at around 7.7 Billion.26
23
‘Real Growth in GDP by volume’, (Eurostat 2016)
<<http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tec00115&plugin=1>>
Date accessed 27/10/16.
24
Paul Hosford, ‘Leprechaun Economics-experts aren’t impressed by Ireland’s GDP figures ‘, (theJournal.ie, 13
July 2016) <http://www.thejournal.ie/gdp-growth-leprechaun-economics-2876138-Jul2016/> Date accessed
27/10/16.
25
Cliff Taylor, ‘Ireland’s GDP figures: Why 26% economic growth is a problem’, Irish Times (Dublin, 15 July
2016).
26
Budget 2017.
8|Page
Global Competitiveness Index
Business
Sophistication
Market Size
Innovation
Technological
Readiness
Institutions
Financial Market
Development
Infastructure
Labour Market
Efficency
Ireland
Advanced Economies
Macroeconomic
Enviornement
Goods Market
Efficency
Health & Primary
Education
Higher Education &
Training
Source: The Global Competitiveness Report 2015-201627
The 2015 market spike may not have immediate drastic impacts as the capital is not yet part
of the economy but the mere fact that these types of moves are taking place may indicate the
confidence of large multinational firms to invest in Ireland as a competitive destination. The
above chart gives Ireland a favourable rating in terms of competitiveness, this along with the
retained corporate tax rate will prove to have an increasingly positive impact on foreign direct
investment.
This may prove decisive, especially when we consider just how many persons are employed
by global multinationals in Ireland, a figure widely quoted as being around the 50% mark for
manufacturing.28 In 2003 up to 70% of exports came from the Computers and Chemical
27
‘The Global Competitiveness Index 2015–2016 Rankings’, < http://www3.weforum.org/docs/gcr/20152016/Global_Competitiveness_Report_2015-2016.pdf> Accessed 27 October 2016.
28
Frances Ruane & Peter J Buckley, ‘Foreign Direct Investment in Ireland: Policy Implications for Emerging
Economies’ (Trinity College, 2006), < https://www.tcd.ie/iiis/documents/discussion/pdfs/iiisdp113.pdf> Date
accessed 28 October 2016.
9|Page
industry.29 This change directly corresponds to the introduction of the 12.5% rate of
Corporation tax introduced in 1976 for trading profits.30
External Trade-Total Imports & Exports
90000
80000
70000
60000
50000
40000
30000
20000
10000
0
1973
1978
1983
Imports (M Euros)
1988
1993
1998
2003
Exports (M Euros)
Source: CSO31
The above findings firmly establish the positive impact of Ireland’s low corporation tax on
Foreign Direct Investment and it is likely that such positive trends should continue. Hence, its
retention has been one of the most important aspects of the budget.
Proposed Measure
The government should introduce a 6% tax on profits generated by SPVs (Special Purpose
Vehicles) that are involved in securitization. It is submitted that the introduction of such a tax
would provide the exchequer with extra finances to benefit Ireland’s business sector in other
areas such as the reduction of the higher personal tax rate. The introduction of such a tax may
also prevent misuse of SPVs that has happened in the past.
29
‘Ireland and the EU 1973-2003’,
<<http://www.cso.ie/en/media/csoie/releasespublications/documents/statisticalyearbook/2004/ireland&thee
u.pdf>> Date accessed 29 October 2016.
30
Aidan Walsh & Chris Sanger, ‘The historical development and international context of the Irish corporate tax
system’, (Ernst & Young, 2014), <
http://www.budget.gov.ie/Budgets/2015/Documents/EY_Historical_Dev_International_Context_Irish_%20Cor
poration_Tax.pdf> accessed 29 October 2016.
31
‘Ireland and the EU 1973-2003’
<<http://www.cso.ie/en/media/csoie/releasespublications/documents/statisticalyearbook/2004/ireland&thee
u.pdf>> Date accessed 29 October 2016.
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SPVs are structures established under s110 of the TCA 1997 in which a qualifying company
holds an asset denominated in a foreign currency in the form of a loan, lease or debt. An asset
must belong to a person who is not a state resident; is not carrying on trade in the state
through a branch or agency or the relevant asset was not acquired by such a branch or agency
operating in the state. Such a company carrying on the business of management of a
qualifying asset must not carry on any other business, apart from activities which are
ancillary to the business management of those qualifying assets. There are various SPVs that
can be set up in Ireland.32 Three reasons for choosing Ireland:
I)
Ireland has an extensive double tax treatment network;
II)
As a member of the OECD and EU it is not considered to be an offshore
jurisdiction;
III)
Irish tax legislation provides for special tax treatment in relation to SPVs.33
If a 6% corporation tax is introduced there will no longer be special tax treatment. However,
the first two reasons will still apply.
Companies such as Deutsche Bank set up companies which buy debt or loans from other
countries and hold them on charitable trusts.34 Any profit generated by these structures are
paid to the parent company effectively tax free.35 The losses caused by these structures could
be in the realm of €1 to 2 billion and that this tax loophole was set up with broad parameters
and not policed properly.36 Reporting requirements have been increased by the Central Bank.
Also, the government are in the process of drafting legislation to better police the use of such
32
‘Special Purpose Vehicles’ (Central Bank of Ireland, June 2016)
<https://www.centralbank.ie/polstats/stats/reporting/Documents/SPV_registration_form_guidance_notes.pd
f> accessed 29 October 2016.
33
‘Ireland as a domicile for special purpose vehicles’, (Dillon Eustace, July 2016)
<http://www.dilloneustace.ie/download/1/Publications/Financial%20Services/Ireland%20as%20a%20Domicile
%20for%20Special%20Purpose%20Vehicles.pdf> accessed 28 October 2016: Bank linked investments which
hold debt, equity, loans and other financial assets; Investment fund linked investments and holding companies
are examples of SPVs that can be established.
34
‘Structured finance SPV administration’, (Deutsche Bank, March 2015).
<http://cib.db.com/img/Factsheet_StructuredFinanceSPVAdmin_v5_SCREEN.pdf> accessed 28 October 2016.
35
‘Establishing SPVs in Ireland’, (Arthur Cox, June 2014) <http://www.arthurcox.com/wpcontent/uploads/2012/05/Arthur-Cox-Establishing-SPVs-in-Ireland-May-2014.pdf> accessed 28 October 2016:
outlines the benefits of SPVs stating that there is no corporation tax leakage; no withholding tax and limited
vat leakage.
36
Charlie Taylor, ‘Calls for more action to stop vulture funds using tax loophole’, Irish Times (Dublin, Sep 7
2016).
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funds.37 But, these restrictions that the Minister for Finance intends to implement will only
apply to ‘specified property business’.38 Nevertheless, the fact that these companies can earn
profits through these structures with paying minimal tax is unacceptable particularly due to
worldwide events such as the commission’s ruling on apple tax in Ireland and the fact that
Brazil has declared Ireland a tax haven.39
Obviously, the introduction of a tax on profits of all s110 would remove the incentive of
many companies to set up such structures in Ireland and they would likely relocate to other
countries such as the Netherlands and Luxembourg who offer securitization structures.40
Furthermore, it generates employment for accountancy and law firms. However, Ireland
would still be a favourable location to establish including the fact that it has an English
speaking workforce; excellent legal and accounting services; and good flight access.
Word Count: 1996
Bibliography
Cases
37
‘S110 reporting requirements for SPVs’, (Deloitte) <https://www2.deloitte.com/ie/en/pages/financialservices/articles/s110-reporting-requirements.html> accessed 28 October 2016.
38
‘Changes to S110 Regime Relating to Irish SPVs holding Irish property assets’ (William Fry, 8 September)
<http://www.williamfry.com/newsandinsights/news-article/2016/09/08/changes-to-section-110-regimerelating-to-irish-spvs-holding-irish-property-assets> accessed 28 October
39
‘State aid: Ireland gave illegal tax benefits to Apple worth 13 Billion’, (European Commission 30 August
2016), <http://europa.eu/rapid/press-release_IP-16-2923_en.htm> accessed 31 October 2016; Paul
O’Donoghue, ‘Ireland is trying to get off a Brazilian Black List for Tax Havens’, (theJournal.ie, 25 September
2016) <http://www.thejournal.ie/ireland-brazil-tax-haven-jbs-2-2990888-Sep2016/> accessed 31 October
2016.
40
‘Structured finance SPV administration’, (Deutsche Bank, March 2015).
<http://cib.db.com/img/Factsheet_StructuredFinanceSPVAdmin_v5_SCREEN.pdf> accessed 28 October 2016.
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1. Stephen court ltd v JA Brown [1984] ILRM 231.
Reports
1. ‘Budget 2017 Submission’ (2016) Irish Tax Institute.
Government Reports
1. Department of Finance, Summer Economic Statement, (2016) ch 1 economic strategy:
outlined the growth of GDP in 2015 was the strongest since 2000.
2. Department of Finance, Summer Economic Statement, (2016) ch 1 economic strategy.
Newspaper Articles
1. Joe Brennan, ‘Panama Papers shine a light on Ireland’s SPVs’ Irish Times (Dublin
April 2016).
2. Charlie Taylor, ‘Calls for more action to stop vulture funds using tax loophole’, Irish
Times (Dublin, Sep 7 2016).
3. Cliff Taylor, ‘Ireland’s GDP figures: Why 26% economic growth is a problem’, Irish
Times (Dublin, 15 July 2016).
4. Ciarán Hancock, ‘Budget 2017: the measures designed to soften blow of Brexit’ The
Irish Times (Dublin, 12 October 2016).
5. Conor O’Brien, ‘Budget 2017 reaction: KPMG Ireland hails ‘cautious and prudent’
budget’ Irish Examiner (Cork, 11 October 2016).
6. Colin Gleeson, ‘The business community has its say on Budget 2017’ The Irish Times
(Dublin, 12 October 2016).
7. Kitty Holland, ‘5,000 new homes a year needed to meet social housing demand’, Irish
Times (Dublin 26 May 2014).
8. Sarah McCabe, Housing shortage: Just 3000 properties for sale in Dublin at present’,
the Irish Independent, (Dublin 22 January 2014).
9. Conor Pope, ‘Dublin hits record high after 10% rise nationwide’, Irish Times (Dublin,
15 Sep 2016).
Websites
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1. Structured finance SPV administration’, (Deutsche Bank, March 2015).
<http://cib.db.com/img/Factsheet_StructuredFinanceSPVAdmin_v5_SCREEN.pdf>
accessed 28 October 2016.
2. ‘Establishing SPVs in Ireland’, (Arthur Cox, June 2014)
<http://www.arthurcox.com/wp-content/uploads/2012/05/Arthur-Cox-EstablishingSPVs-in-Ireland-May-2014.pdf> accessed 28 October 2016.
3. ‘S110 reporting requirements for SPVs’, (Deloitte)
<https://www2.deloitte.com/ie/en/pages/financial-services/articles/s110-reportingrequirements.html> accessed 28 October 2016.
4. ‘Changes to S110 Regime Relating to Irish SPVs holding Irish property assets’
(William Fry, 8 September) <http://www.williamfry.com/newsandinsights/newsarticle/2016/09/08/changes-to-section-110-regime-relating-to-irish-spvs-holding-irishproperty-assets> accessed 28 October
5. ‘State aid: Ireland gave illegal tax benefits to Apple worth 13 Billion’, (European
Commission 30 August 2016), <http://europa.eu/rapid/press-release_IP-162923_en.htm> accessed 31 October 2016; Paul O’Donoghue, ‘Ireland is trying to get
off a Brazilian Black List for Tax Havens’, (theJournal.ie, 25 September 2016)
<http://www.thejournal.ie/ireland-brazil-tax-haven-jbs-2-2990888-Sep2016/>
accessed 31 October 2016.
6. ‘Structured finance SPV administration’, (Deutsche Bank, March 2015).
<http://cib.db.com/img/Factsheet_StructuredFinanceSPVAdmin_v5_SCREEN.pdf>
accessed 28 October 2016.
7. ‘Special Purpose Vehicles’ (Central Bank of Ireland, June 2016)
<https://www.centralbank.ie/polstats/stats/reporting/Documents/SPV_registration_for
m_guidance_notes.pdf> accessed 29 October 2016.
8. ‘Ireland as a domicile for special purpose vehicles’, (Dillon Eustace, July 2016)
<http://www.dilloneustace.ie/download/1/Publications/Financial%20Services/Ireland
%20as%20a%20Domicile%20for%20Special%20Purpose%20Vehicles.pdf> accessed
28 October 2016.
9. Frances Ruane & Peter J Buckley, ‘Foreign Direct Investment in Ireland: Policy
Implications for Emerging Economies’ (Trinity College, 2006), <
14 | P a g e
https://www.tcd.ie/iiis/documents/discussion/pdfs/iiisdp113.pdf> accessed 28
October 2016.
10. ‘Ireland and the EU 1973-2003’,
<http://www.cso.ie/en/media/csoie/releasespublications/documents/statisticalyearboo
k/2004/ireland&theeu.pdf> accessed 29 October 2016.
11. Aidan Walsh & Chris Sanger, ‘The historical development and international context
of the Irish corporate tax system’, (Ernst & Young, 2014), <
http://www.budget.gov.ie/Budgets/2015/Documents/EY_Historical_Dev_Internationa
l_Context_Irish_%20Corporation_Tax.pdf> accessed 29 October 2016.
12. ‘Ireland and the EU 1973-2003’
<<http://www.cso.ie/en/media/csoie/releasespublications/documents/statisticalyearbo
ok/2004/ireland&theeu.pdf>> Date accessed 29 October 2016.
13. ‘The Global Competitiveness Index 2015–2016 Rankings’, <
http://www3.weforum.org/docs/gcr/20152016/Global_Competitiveness_Report_2015-2016.pdf> Accessed 27 October 2016.
14. Real Growth in GDP by volume’, (Eurostat 2016)
<http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=te
c00115&plugin=1> accessed 27 October 2016.
15. Paul Hosford, ‘Leprechaun Economics-experts aren’t impressed by Ireland’s GDP
figures ‘, (theJournal.ie, 13 July 2016) <http://www.thejournal.ie/gdp-growthleprechaun-economics-2876138-Jul2016/> Date accessed 27/10/16.
16. Department of Finance, UK EU Exit - An Exposure Analysis of Sectors of the Irish
Economy (Government of Ireland, 2016) 6.
17. Mark Fielding, ‘Budget 2017 Government Must ‘Think Small First’’ (Irish Small and
Medium Enterprise Association, 20 July 2016) < http://isme.ie/budget-2017government-must-think-small-first> accessed 26 October 2016.
18. Mark Fielding, ‘Budget 2017 Government Must ‘Think Small First’’ (Irish Small And
Medium Enterprise Association, 20 July 2016) < http://isme.ie/budget-2017government-must-think-small-first> accessed 26 October 2016.
19. John McSweeney, ‘Challenges facing SMEs in the current climate’ (Institute of
Directors in Ireland, 27 April 2015) < https://www.iodireland.ie/newsevents/blog/challenges-facing-smes-current-climate> accessed 27 October 2016.
15 | P a g e
20. Paul O’Donoghue, ‘Budget 2017: The budget has failed to deliver for small
businesses’ (the journal, 11 October 2016) < http://www.thejournal.ie/capital-gainstax-budget-shares-2-3021506-Oct2016/> accessed 26 October 2016.
21. John Kennedy, ‘Budget 2017: Caulfield says capital gains tax cut is ‘peanuts’’
(Siliconrepublic, 11 October 2016) < https://www.siliconrepublic.com/startups/capital-gains-tax-caulfield-budget-2017> accessed 25 October 2016.
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