As we start a new year, we present a look back at the work, legal developments and team growth that kept us busy in 2024.

Expansion and Developments

Elaine Mooney has been elevated to the partnership from 1 January 2025. 

We have expanded the group in the past year and have been joined by tax lawyers from New Zealand and South Africa, and this week welcome tax lawyers back from a period in London and from other leading Irish firms. 

Recognition

Legal 500 EMEA

Arthur Cox maintained its band 1 ranking for Chambers Europe and tier 1 ranking for The Legal 500 EMEA 2024.

• Fintan Clancy, Partner – Hall of Fame
• Ailish Finnerty, Partner – Leading Practitioner
• David Kilty, Partner – Leading Practitioner
• Orlaith Kane, Partner – Recommended

Chambers Europe

Tax partners Fintan Clancy, Ailish Finnerty and David Kilty were recognised in the individual rankings.

International Tax Review (ITR) World Tax Leaders 2024

Six lawyers from our Tax Group ranked:

• Fintan Clancy, Partner – Highly Regarded
• Ailish Finnerty, Partner – Notable Practitioner
• David Kilty, Partner – Highly Regarded
• Orlaith Kane, Partner – Highly Regarded
• Elaine Mooney, Partner – Rising Star
• Dearbhla Ní Fhloinn, Senior Associate – Rising Star

Notable Transactions

Archer Hotel Capital B.V acquisition of the Shelbourne Hotel
Tax partner Orlaith Kane and associates Isobel D’Arcy and Ruth O’Sullivan advised the investment firm, Archer Hotel Capital B.V. on all Irish tax aspects of its acquisition of the landmark Dublin hotel, the Shelbourne Hotel, from investors, Kennedy Wilson. Arthur Cox had previously advised Archer Hotel Capital B.V. on the acquisition of the Conrad Hotel in 2019. The sale of the Shelbourne Hotel was worth €260 million and was a landmark deal in the Irish market for 2024. Read more here.

Strategic Value Partners acquisition of Blanchardstown Centre
Tax partner Ailish Finnerty, senior associate Cristina Susanu and associate Ciara Murphy advised Strategic Value Partners, LLC on the signing of its acquisition and financing of Blanchardstown Centre, one of Ireland’s leading shopping destinations. Read more here.

Sale of majority stake in the Dean Hotel Group
Tax partner David Kilty and senior associate Paulina Serafieva advised the Dean Hotel Group on its completion of the landmark sale of eight hotels on the island of Ireland, and its entry into a strategic partnership with Lifestyle Hospitality Capital (LHC) and Elliott Investment Management. Read more here.

Flutter’s acquisition of an initial stake in NSX Group and acquisition of Snaitech
Arthur Cox advised our long-standing client Flutter Entertainment plc, the world’s leading online sports betting and iGaming operator, on its acquisition of an initial 56% stake in NSX Group, a leading Brazilian sports betting and iGaming group and operator of the flagship Betnacional brand. Tax partners David Kilty and Elaine Mooney acted for the tax team. Read more here.

David Kilty and associate Rachel Coyle advised Flutter Entertainment plc on its acquisition of Snaitech, one of Italy’s leading omni-channel operators, from Playtech plc. Read more here.

R&S Group Holding AG acquisition of Kyle Powertech Limited
Arthur Cox advised R&S Group Holding AG, a leading provider of electrical infrastructure, on the acquisition of 100% of Kyte Powertech Limited, an Irish leading manufacturer of distribution transformers, from MML Growth Capital Management Partners and existing management. Tax partner Ailish Finnerty and senior foreign registered Lawyer Lebo Motsumi Nkoloti acted for the tax team.

Channel Mechanics sale to Allbound
Tax partner Ailish Finnerty, senior associate Paulina Serafieva and associate Ciara Murphy advised the shareholders of Channel Mechanics on its sale to Allbound, creating the most comprehensive Partner Relationship Management (PRM) platform in the industry. Read more here.

Kerry Group’s sale of Kerry Dairy Ireland
Tax partner Ailish Finnerty and associate Ruth O’Sullivan acted for the tax team in advising Kerry Group on the proposed sale of its dairy consumer products and dairy ingredients business to Kerry Co-Operative Creameries. Read more here. 

Sale of Chanelle Pharma to Exponent
Tax partner Orlaith Kane and senior associate Cristina Susanu advised Channelle Pharma on the sale of the company by founder Michael H Burke for approximately €300 million to Exponent, a British private equity group. Chanelle Pharma is the largest producer of generic medications for humans and animals in the State and is considered one of Ireland’s most successful companies. Read more here.

Phoenix Tower International acquisition of Cellnex Telecom
Tax partner Ailish Finnerty advised Phoenix Tower International on its acquisition of Cellnex Telecom’s business in Ireland for approximately €971 million. Read more here.

TE Connectivity plc’s re-domiciliation to Ireland
Tax partner Orlaith Kane, senior associate Paulina Serafieva and associate Ruth O’Sullivan acted for the tax team in advising TE Connectivity, a global industrial technology leader, on the successful re-domiciliation of its publicly traded parent company from Switzerland to Ireland. Read more here.

Aptiv plc’s re-domiciliation to Switzerland
Tax partner Fintan Clancy and senior associate Paulina Serafieva advised Aptiv, a publicly listed, leading global automotive technology company on its successful re-domiciliation of its head office from Ireland to Switzerland.

Element Fleet Management
Tax partner Orlaith Kane, and associate Rachel Coyle advised Element Fleet Management on the establishment of a centralised leasing function in Dublin. Element Fleet Management Corp is the largest publicly traded, pure-play automotive fleet manager in the world.

Softbank’s investment in Cubic Telecom
Tax partner David Kilty and senior associate Cristina Susanu advised Cubic Telecom on Softbank’s investment of approximately €473 million in Cubic Telecom at a valuation of over €900 million. The investment is believed to be the largest ever software deal in Ireland.  Read more here.

Intrum Holding AB on sale of portion of investment portfolio
Tax partners Fintan Clancy and Elaine Mooney advised Intrum Holding AB, one of Europe’s largest non-performing loan servicers, on its agreement to sell a material portion of its investment portfolio to affiliates of Cerberus Capital Management L.P. The transaction involved over 10,000 portfolios with a nominal value of SEK 382 billion (EUR 33 billion) and a book value of SEK 11.5 billion (EUR 1.0 billion) as of 30 September 2023.  Read more here.

Merger of Allkem Ltd and Livent Corporation
Tax partner David Kilty and senior associate Cristina Susanu advised Allkem Ltd on the completion of the all-stock merger of equals with Livent Corporation. The top holding company of the group is an Irish tax-resident entity. The new combined company is a leading global lithium chemicals producer and the third biggest in the world.

Bank of Cyprus Holdings plc: Listing on Athens Stock Exchange (ATHEX)
Arthur Cox acted as lead legal adviser to Bank of Cyprus Holdings plc on its listing on the Athens Stock Exchange (ATHEX) and delisting from the London Stock Exchange (LSE) in a first of its kind transaction for an Irish company. Tax partners Fintan Clancy and Elaine Mooney and senior foreign registered lawyer Lebo Motsumi Nkoloti acted for the tax team. Read more here.

Oaktree and LED Group Partnership
Arthur Cox advised LED Group on its partnership with Oaktree Capital Management to develop a leading platform for building electrification products and energy transition solutions. Tax partner Orlaith Kane and associate Isobel D’Arcy acted for the tax team. Read more here.

Acquisition by LCM Partners of part of Oaktree’s Spanish real estate lending business
Tax partner Orlaith Kane and senior associate Paulina Serafieva also advised LCM Partners, a leading European Alternatives Investment Manager, on the acquisition of part of the real estate lending business of Oaktree Capital Management.

Mallinckrodt’s disposal of its global Therakos business
Tax partner Orlaith Kane and other members of the tax team advised Mallinckrodt on the disposal of its global Therakos business to CVC for a purchase price of approximately $925 million. 

Sale of Barclays Bank’s German consumer finance business
Tax Partner Fintan Clancy and senior associate Dearbhla Ní Fhloinn advised Barclays Bank on the sale of its German consumer finance business by way of an Irish scheme of arrangement.

Tax Litigation
The tax litigation team is an integrated practice of tax and litigation specialists. In 2024 the tax litigation team represented clients before the Tax Appeal Commission, where the team has a 100% success rate.

In 2024, tax partner Fintan Clancy and litigation partner Jack Logan represented Covidien Limited before the High Court and Court of Appeal on the issue of VAT and holding companies. Covidien Limited was successful before the Tax Appeal Commission and the High Court and judgment is awaited from the Court of Appeal. 

Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APA)
In 2024, tax partners, Fintan Clancy, Ailish Finnerty, Orlaith Kane and David Kilty have worked on MAPs and APAs for Irish resident companies with the US, Canada, Germany, Korea, Luxembourg and Spain amongst others.

Irish implementation of Pillar Two

The tax department has advised its clients on complex and novel issues arising from the Irish implementation of the EU Directive ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups (“Pillar Two”) .

Pillar Two was transposed into Irish law from 1 January 2024. Tax partner Ailish Finnerty has advised on a range of matters including constitutional law issues, and the application of the Irish general anti-avoidance rule. Tax partners David Kilty and Fintan Clancy have provided extensive advice on the application of the rules to securitisation entities and shipping companies and tax partner Orlaith Kane has advised on a range of issues arising in the course of mergers and acquisitions. 

Tax Policy

The Tax Group is involved in the development of Irish tax policy and Ireland’s response to international tax reform. In 2024, the tax team engaged extensively in 2024 with the Irish Department of Finance, the EU Commission and OECD on new legislative proposals, responding to public consultations, legislative feedback statements and liaising with the Irish Department of Finance and European Commission on specific matters of concern for clients.

We frequently liaised with the Department of Finance on the scope of the new Irish dividend participation exemption, particularly in relation to the draft legislative text that was published in August. Our contributions sought to ensure that a broad, competitive, and easy to administer regime was introduced; one that is no more restrictive than our EU partners.

Background on the Tax Group

The Arthur Cox tax group is one of the leading tax law practices in Ireland.  We provide fully comprehensive and commercial tax advice to a broad range of domestic and international clients operating in all sectors of the Irish economy. 

We provide high value advice on important transactions and challenging situations. Our team is an integrated part of the firm’s wider legal practice for clients but also provides stand-alone tax advice.

We have a highly experienced team made up of five partners, one Of Counsel, one tax director, thirteen associates, one knowledge lawyer, one paralegal and trainees.