Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / research-memo-irish-tax-treaty.docx
research-memo-irish-tax-treaty.docx
Parties
HARKNESS LLP
Ireland Inc
Solstice Medical Technologies Inc
SMT Inc
Solstice Biomedical Devices Ltd
Whitmore Valuation Advisors LLC
Structure Solstice Biomedical Devices Ltd
Pemberton Hale LLP
Dates
December 31, 2023
January 18, 2024
January 29, 2024
March 1, 2034
March 1, 2024
January 1, 2015
March 8, 2024
January 1, 2020
Amounts
€13.12
$1.09
€347.6
€78.4
€10
$189.2
$174.8
€1,000
$214.5
€180.0
Obligations
The claimant company must be carrying on a trade for the purposes of which the specified intangible assets are used
In order for SIP Holdings to fully absorb these deductions, its trading income (before such deductions) must equal or exceed: €19
SIP Holdings must be centrally managed and controlled in Ireland in order to be treated as Irish tax resident
C, SIP Holdings' trading income must equal or exceed approximately €24
75% fixed) must be arm's-length under Irish transfer pricing rules (discussed further in Section IV below)
The purchase price must be demonstrated to be arm's-length for Irish transfer pricing purposes