Caroline Devlin

  • Caroline Devlin
  • PARTNER, CO-CHAIR AVIATION GROUP
  • +353 1 920 1224
  • Arthur Cox, Ten Earlsfort Terrace, Dublin 2, D02 T380, Ireland

Expertise

Caroline is co-chair of our Aviation Group. She is also a senior partner in our Tax Group. She has extensive experience in advising both domestic and international companies on structuring their tax affairs for various types of transactions including establishing operations in Ireland, mergers and acquisitions, intellectual property structures, reorganisations and restructurings. She is particularly experienced in advising clients on all financial services transactions including loan portfolio transactions, securitisations, bond issues, and aircraft and equipment leasing. Caroline is also very experienced in navigating a path through tax disputes and tax litigation for clients. Caroline leads the firm’s Asia-Pacific Group.

Experience

Caroline has recently advised in the following areas:

  • Tax issues associated with setting up in Ireland including tax aspects of servers located in Ireland, maximising tax incentives available in Ireland, efficient repatriation of profits, tax aspects relating to data and IP in Ireland and other tax advices
  • Intellectual property structuring, including moving IP into and out of Ireland, managing withholding taxes, devising structures to maximise allowances, either onshore or through bespoke transactions
  • Advising lenders, lessors, lessees and airlines on Irish tax related matters in the establishment and maintenance of Irish aircraft leasing platforms and providing insight in relation to the impact of OECD Base Erosion and Profit Shifting (BEPS) measures and EU Anti-Tax Avoidance Directives on the aircraft leasing sector
  • Financing and securitisation transactions for various asset classes and jurisdictions including Russia, Germany, France, China, Korea, UK and US
  • FinTech transactions including advising on Initial Coin Offerings (ICOs).
  • Private equity firms on Irish tax aspects of acquiring property loan books, which involves all tax aspects of dealing in loans and property based transactions
  • Tax issues arising relating to capital raising by Irish banks and non-Irish banks
  • Universities seeking an outward expansion into other jurisdictions in a tax efficient manner

Examples of recent matters that Caroline has advised on include:

  • Facebook Ireland Limited on the leasing and redevelopment of their new 14 acre international HQ at AIB Bankcentre and Fibonacci Square, Ballsbridge
  • Genomics Medicine Ireland Limited on its acquisition by WuXi NextCode
  • Kennedy Wilson on its acquisition of a mixed-use development sites in Dublin’s North Docks
  • Paddy Power Betfair in relation to its share buyback on the London stock exchange
  • Total Produce plc on the acquisition of a 45% interest in Dole Food Company
  • Hines, the international real estate firm, on its acquisition of Chatham & King, a mixed-use property asset in Dublin, on behalf of the Hines Pan-European Core Fund from an affiliate of Lone Star Real Estate Fund III
  • Brunswick Rail Finance DAC issuance of $600m Notes in the context of a corporate restructuring
  • Review of the international business model and supply chain of a retailer which operates in over 100 jurisdictions worldwide and advising on VAT arrangements, supply chains and agency issuers in relation to the pan-European supply of goods
  • A US client in relation to its dispute with the Irish tax authorities over taxing rights and information provision requirements applicable to taxpayers
  • The Depositary Trust Company (DTC) on Irish tax issues in connection with DTC offering its depository, book-entry transfer and clearing and settlement services to Irish incorporated companies with listings on US stock exchanges such as Eaton, Jazz Pharmaceuticals, Fleetmatics, Medtronic, Pentair, Elan and others
  • Paddy Power on the tax aspects of its merger with Betfair
  • Platform Specialty Products on the tax aspects of its $3.51 billion acquisition of Arysta Life Science

Memberships

  • Institute of Taxation in Ireland
  • Law Society of Ireland Taxation Committee
  • Member and Past Chairman of the Main Taxation Administration Liaison Committee (TALC)
  • Member of TALC BEPS Implementation Sub-Committee