Financing Activities
A Variety of financing activities may be possible. There will no longer be any need to route international financial activities through the IFSC/Shannon licensed structures.

Distribution and Professional Services
Under the 12.5% rate applies to distribution, marketing and professional services activities.

Headquarter Activities
Under the 12.5% regime, it should be possible to include headquarters or administrative functions.

Software
A number of restrictions currently apply to the type of ‘software’ related activities which qualify for the ‘10%’ rate of corporation tax. However, all software related trading activity should qualify for a minimum rate of 12.5% corporation tax.

Intellectual Property Rights
The 12.5% rate applies to any exploitation of intellectual property which does not qualify for the 10% rate.