Dr. Brian Keegan:

If there is a manufacturing company with a surplus which is looking for an investment for that surplus, it might invest in REITs. The return on the REIT is passive in nature. It is taxed at 25% on that. Banks and institutional investors tend, going back to our first example about passive investment, to actively manage their investments. Therefore, the rate which is attracted is 12.5%. As a general principle, there is no tax on inter-company dividends within Ireland because the notion is that an Irish company has already paid its tax and is paying a dividend to another Irish company so there would be a double charge of tax if there was tax on those dividends. That, in very broad terms, describes the three.