The recently published BEPS Action plan should be seen as a real opportunity for Ireland, and its Foreign Direct Investment strategy.

The new BEPS rules, which link Substance (such as real decision making and R&D) to where profits are taxed should result in multinationals continuing to affirm Ireland as a good location to invest in and conduct business from.

Ireland has operated a substance based FDI strategy for decades.

Whilst the Irish government may need to look at income tax rates in order to ensure that senior decision makers locate here, the fact that that "Substance" strategy has already resulted in significant multinationals setting up real operations here should see Ireland, and its attractive 12.5% Corporate tax rate, continue to attract real investment.