Configuraciones necesarias para implementar el servicio AVL EDGE/GPRS.

companies to undertake new or additional R&D in Ireland. The tax credit is available to Irish resident companies and branches on the extra cost of in-house R&D undertaken within the European Economic Area (EEA), provided such expenditure is not otherwise eligible for tax benefits elsewhere within the EEA. Incremental spend is calculated in comparison to a base year of 2003 for R&D expenditure in excess of €100,000. So, for new entrants to R&D, the credit is essentially based on the volume of work undertaken. To qualify for the tax credit, applicants must seek to achieve a scientific or technical advancement. The work must also help to resolve scientific or technological uncertainty. Both revenue and capital expenditure may qualify. In practice, this includes wages, related overheads, the cost of plant and machinery and buildings. The credit regime also provides for outsourcing so that up to 5% of the expenditure on R&D can be passed on to European universities, including Irish ones. In addition, 10% of the expenditure can be subcontracted to other unconnected parties (i.e., giving a total of 15%), or €100,000, whichever is the greater amount. The tax credit can be refunded over three years where there is insufficient corporate tax liability to utilize the full credit in a particular year, or otherwise can be carried forward.

Tax landscape for investors

In certain circumstances, interest paid on loans used to invest in a partnership in which the borrower is an active partner, may be allowed in whole or in part as a deduction from total income. However, a similar allowance for investment in companies was abolished at the end of 2010.

Tax landscape for entrepreneurs

The Business Expansion Scheme (BES) is an incentive which provides tax relief for investment by entrepreneurs and others in certain corporate trades. The scheme allows an individual investor to obtain income tax relief on investments up to a maximum of €150,000 per annum in each tax year up to 2013. Relief is available at the investor’s highest rate of income tax. Investors who cannot obtain relief on all their investment in a year of assessment, either because the investment exceeds the maximum amount or because their income in that year is insufficient to absorb all of it, can carry forward the unrelieved amount to following years up to and including 2013. Such rules are subject to the normal limit of €150,000 on the amount of investment that can be relieved in any one year.

In order to qualify for the relief, investments must be made in companies engaged in certain areas of manufacturing, services, tourism, R&D, plant cultivation, the

construction and leasing of advance factories or in certain areas of music recording. The investee companies must be unquoted, i.e., they must not be on the official list of a stock exchange.

A further relief for seed capital provides that individuals who leave employment to start up their own businesses may claim a refund of tax on previous income for up to six years in respect of the investment in the new business. Individuals can select the tax years for which they may claim refunds from any or all of the six years prior to the year of investment. The maximum relief is €100,000 per annum at the individual’s top rate of tax.

Finance

A range of services and incentives, including funding and grants, are available to those considering foreign direct investment in Ireland. These are offered to both new and existing clients by IDA Ireland, an agency which promotes inward investment. IDA assists in the process via a range of services which include information and statistics on business sectors and locations within Ireland; assisting in setting up a business; and introducing potential investors to industry in Ireland, to government representatives and those providing services and research. Where required, the agency may also offer advice on property for international investors (http://www.idaireland.com). Enterprise Ireland (EI) is the state agency responsible for supporting the development of manufacturing and international

service companies. The agency provides funding and support to everybody from entrepreneurs with plans for a start-up to large companies planning to expand their activities or seeking to grow their exports. There are a number of schemes available, for example a large company undertaking a large R&D project could receive €650,000. EI (www.enterprise-ireland.com) also provides funding and support for college-based researchers to assist in the development, protection and transfer of technologies to industry via licensing or through spin-out companies. Science Foundation Ireland (SFI; www.sfi.ie) invests in academic researchers and teams likely to generate new knowledge, technologies and competitive enterprises in science and engineering. It also aims to encourage a culture of entrepreneurialism and promote partnerships (www.sfi.ie).

25%

Availability of capital

Despite the economic difficulties in Europe, capital is still available for start-ups and other enterprises from state agencies such as IDA and Enterprise Ireland, as well as investors, venture capitalists and banking institutions.

Regulatory environment

and incentives

Under European and Irish legislation, all medicinal products must be authorized by the Irish Medicines Board (IMB; www.imb.ie) before being marketed in Ireland.

Authorization to market a product or service produced through biotechnology may be obtained by taking one of several routes. First, there is a direct approach to the IMB. This should be used only to market the product in Ireland and not in any other Member State of the European Union, or as the basis for a future application for mutual recognition to other Member States. Second is what are known as mutual- recognition and decentralized procedures. Both aim to facilitate access to a single market by relying on the principle of mutual recognition.

Third is a centralized procedure. The European Medicines Agency (EMA) is responsible for the scientific evaluation of applications made in this way. Companies are required to submit a single application for authorization to the EMA.

Structuring for the future