Technical notebook

An intermediary recently asked a question in relation to a client who is an Irish national resident in France who wishes to effect an offshore bond. What would be the tax treatment of this investment, assuming it is encashed either in France or when the y return to Ireland? The tax treatment would depend on whether the bond is issued by a company that has specific approval to do business in France. This is not easy to achieve if you are not a French insurer, even if you are based in another EU country. However, EU freedom of services provisions are becoming increasingly persuasive. The tax ...