Denis O'Brien, Parteney Ltd, Residential Property and Tax Avoidance

Interesting article in the Irish Times today about Revenue chasing Denis O'Brien for €57 million in capital gains tax.

The issue of residency has come up in the case, including details of a house owned by a company called Parteney Ltd which was earmarked as a future residential house for O'Brien and his family.

Let's forget about O'Brien here for a moment. The real story here I think is the method by which high-net-worth individuals such as O'Brien can use Ireland's company and tax law to acquire property and avoid tax while doing so.

 I'm going to have to do a bit more digging into the actual way it is done, but property owned by a company is NOT treated the same way as property owned by an individual. And whatever O'Brien was doing here, I'd say it's almost certain that it is common practice among certain circles of Irish society.

 Anyway, the Irish Times article, along with the company details for Parteney Ltd and the names of the directors and the other companies of which they are directors. PDF of file available to download here.

Padriac White and the Establishment of the IFSC

The following extract is taken from The Making of the Celtic Tiger: The Inside Story of Ireland's Boom Economy. Dublin. Mercier Press. (2000). It is Padraic White's own account of the development of the Irish Financial Services Centre.

In the middle of 1973, the IDA launched international services as its latest product. At the time, this category included both technical consultancy services and computer services. However, within the IDA's own research unit, work continued to identify and analyse other service products, including those n the financial-services area. One of the economists engaged in this task was Ken O'Brien, who later, as founder of Finance magazine, would provide specialist coverage of the Dublin financial centre. Our New York office befriended a Wall Street lawyer, Bob Slater, who was familiar with the then-exotic world of offshore banking - the reasons why banks set up in specialist offshore centres, the kind of financial activities undertaken there and the nature and number of jobs created in this developing sector. 

As manager of the planning unit, I agreed to take on Bob Slater, both as a financial consultant on financial services to IDA and to produce a study of offshore banking systems. His report examined the success of Bermuda in creating jobs in financial services, and he was satisfied that Ireland could emulate its achievement. And so in 1978 - innocently, in hindsight - we set out to promote international financial services to the world, and did so on a pilot basis to test-market the reaction. The IDA executives embarked on their selling mission, armed with the expert conclusions of the Wall Street expert. 

During the year the IDA team soon landed some big fish in the form of two US banks that had developed specific job-creating proposals. However, the agreement of the Central Bank was first needed. Michael Killeen* considered the proposals sufficiently important for himself to go with Jerry Kelly, who was negotiating the projects, and myself to make the case for Central Bank authorisation. The reaction was not encouraging and we left the Dame Street offices feeling rather dejected. We could not give the required assurances or promises of authorisations to our foreign bank clients. The projects died and we ceased to do any more financial-services promotion. Subsequently, it emerged the bank no stomach for the projects and would not approve them. However, the IDA could never get a clear reason for this. The most authoritative word which came back indirectly was that the Central Bank believed the offshore financial projects 'smacked of a banana republic.' (pp.323-4.)

Padriac White was born in 1942 and educated at De La Salle College, Ballyshannon, Donegal.** He graduated from UCD with a B.Comm (hons) and went on to complete a diploma in Public Administration. He entered the civil service as an Executive Officer with the Department of Defense in 1960. In 1964 he was promoted to Administrative Officer and was positioned with the Department of Health. He joined the Industrial Development Authority (IDA) in 1970 as a regional planning officer. He became the managing director of the IDA in 1980. He held this position until 1990.

Bloomberb Businessweek gives the following as background on Padraic White as an investment professional with Kernal Capital:

Mr. Padraic White serves as an Investment Professional of Kernel Capital. Mr. White served as the Managing Director of the Industrial Development Authority (IDA-Ireland) until June 1990. He served as the Chief Executive Officer of the Irish Development Authority. Mr. White has advised governments around the world on the promotion of foreign direct investment as a Senior Consultant for FIAS (World Bank), EU Phare, and the Department of Foreign Affairs. Mr. White serves as the Chairman of Senior Advisory Board at SolarPrint Limited. He served as an Interim Chairman of Northern Ireland Water Limited. Mr. White serves as a Director of a number of financial services companies such as Willis Risk Services Ltd. (Ireland); London Life & General Re-insurance Ltd. (Ireland); and Canada Life International Ltd. (Ireland). He has a strong interest in indigenous enterprises chairing a diverse array of small and medium enterprises in wind energy, smokeless fuel, solar cells, radio, recruitment, and accredited certification. Mr. White is well known for his role with large scale international companies and has extensive experience over the past 20 years in the Irish small and medium enterprises sector. Mr. White served as the Chairman of Cable Management Ireland Ltd. He serves as Chairman of the Enterprise Council of West Belfast and Greater Shankill and of the Louth Economic Forum. He serves as Chairman of Investment Committee at Bank of Ireland Seed and Early Stage Equity Fund.

The website for Kernal Capital gives this as background information:

Padraic White is Chairman of the Investment Committee of the Bank of Ireland Seed & Early Stage Equity Fund. As former Managing Director of the Industrial Development Authority (IDA) from 1980 - 1990, Padraic is engaged in a wide range of commercial, community and public interest activities. Since 1990, Padraic has taken a strong interest in indigenous enterprises and is currently Chairman and Non Executive Director of several private companies including; Certification Europe, Collins McNicholas Recruitment & HR Services, Willis Risk Services (Ireland ) Ltd, Arigna Fuels and Canada Life International Re. His community interests include Chairman of the Enterprise Council of West Belfast & Greater Shankill and of the Employment Services Board for the same area as well as Chairman of Coolock Development Council, Dublin and of the Louth Economic Forum.

The pdf of the chapter is available to download here:



* Michael J. Killeen: Born 1928. Educated St. Joseph's College, Galway; University College Galway; Trinity College Dublin; moderatorship economics and political science; married Mary Kennedy; three sons, two daughters; worked in Department of Industry and Commerce 1945-1952; joined  CTT as Secretary, 1957, Deputy Manager, 1963, General Manager 1967-69, Managing Director IDA, currently [1984] chairman; former chairman AnCO; member, Irish Export Board; member, Irish Management Institute; lecturer, Marketing, Trinity College Dublin 1960-64; chairman of the expanding Irish Distillers Group; director, Central Bank; one of the most significant contributors to the evolution of Irish industry internationally; has forged his way to the top but does not appear to have made enemies en route; a staunch supporter and fund raiser for Fine Gael. [Who's Who in Ireland (1984)]


** Details of Padraic White's life to 1980 taken from Who's Who in Ireland: The Influential 1,000. Dublin: Vesey Publications, 1984.

Money and Money Systems - the Social Weight of Thin Air

I've a lot of time for Richard Murphy but while money can appear to be made "out of thin air" it's only because of the money system that underpins it - and money systems are NOT made out of thin air. I think this point gets lost a lot of the time, that the focus on the money "thing" is one that loses sight of the strong social, political, legal, economic and cultural forces that give a "thing" made "out of thin air" its gravity. It is the movement within the money system that gives money its weight.

 To be fair to Richard Murphy he is well aware of the class dynamics at play within the money system, I only highlight the post as it is an example of the "made out of thin air" argument which treats money as if it exists outside of social dynamics.

 Richard is right in that money is a claim on wealth, and that bank money is essentially credit, and that it is the user who converts credit into money, but the "made out of thin air" is a bit like saying Google searches just "appear" on the screen, with no reference to the vast server farms which underpin Google. While money may appear to be ephemeral, money systems are anything but. And in money systems lies class power.

 Richard Murphy's post: http://www.taxresearch.org.uk/Blog/2013/03/12/all-money-is-a-confidence-trick-3/

Finance (Dublin) 1991 - a selection

First Saudi Ucits Fund to Open in Dublin

Selections from Finance (Dublin) Magazine, 1989

 Haven't had time to really go through these articles, but the main elements which stand out are: BES Schemes ; IFOX ; De-regulation

Selections from Finance Dublin Magazine, 1988

These scanned pages are intended as an aid to research into the world of finance in Ireland. I'm going to try to post as much of the primary and secondary source material I come across as I can. The purpose here is purely educational.

Some quotes, just to give a sense of the articles below.

First, from Ray Douglas, group general manager, Treasury, of Allied Irish Banks, talking about Dublin's biggest dealing room (January 1988, pp.37-38):

The commissioning of our new 80-position dealing room is Bankcentre is only the latest step in a long association between Allied Irish Bank and the global financial markets. In the mid-1970s AIB identified the emerging global financial markets as a major business opportunity for the bank... Our objective is to make AIB a significant niche player in the markets, trading on our own account, providing liquidity to the markets and acting as market maker in some specific areas...
During the 1980s the emergence of the new global financial markets in securities and in off-balance sheet instruments such as SWAPS* and FRAs** has provided a further range of opportunities for AIB.

* SWAP
**Forward Rate Agreement

Ireland had been hot-wired into the world of swaps, derivatives and other off-balance sheet activities for at least twenty years before the crash of 2008. This was no 'bad apple' scenario.

The Feb 1988 issue has a handy guide to pricing options and their reliance on the Black-Scholes Model.

Over the past fifteen years there has been phenomenal worldwide growth in the popularity of options. This trend has been manifested in Ireland by the proposed opening of organised trading exchanges.

March 1988 has an article on indigenous Irish financial engineering:

The latest, and hottest, piece of financial engineering in Ireland resolves around the Business Expansion Scheme (BES). It is popular, too, for there is a last minute rush of funds into the scheme, aiming to beat the April 5th deadline, which is the cut off date for the applicability of personal tax relief, which is by and large the main basis of the current excitement about BES schemes.
BES schemes, allowing personal investors up to £25,000 each in tax relief on investments have been sprouting up all over in the past two months - marketed by fund management companies, stockbrokers, and indeed, private companies aiming to increase their capital.

The same month saw the establishment of Ireland's first futures and options exchange - again marking the continuing financialization of the Irish economy.

A private placing for the new Irish Futures and Options Exchange (IFOX) takes place this month, setting the scene for the emergence of a new dimension in Ireland's money and capital markets with the start up of the Exchange scheduled for mid year. 

Thus Ireland will join the growing number of European countries who have developed domestic futures and options exchanges as facilities to manage risk.

The PDF of the articles for 1988  - thirty-eight pages in total - is here: