Tax and trade policy shifts are contributing to corporate footprint optimisation across Ireland-domiciled enterprises, in turn driving carve-outs.

“A lot of our clients are engaging in contingency planning, which may lead to carve-outs and other deal structures.” Christopher McLaughlin, a Dublin-based partner in Arthur Cox’s Corporate and M&A Group, said.

Ireland’s low corporation tax rate of 12.5% has long provoked concern stateside, with former US presidents Barack Obama and Joe Biden both making moves to repatriate tax revenues. In a rare example of bipartisan consistency, President Donald Trump has also been keen for movement on this agenda. Prior to taking office, Trump’s Commerce Secretary Howard Lutnick dubbed it “nonsense that Ireland of all places runs a trade surplus at our expense”.

Against that backdrop, it’s perhaps unsurprising we’ve seen the annual carve-out deal count rise more than 2.5x since 2015. Carve-outs are effective at shedding operations that could become less profitable amid global policy changes, or re-engineering where profits are generated within a group.

What’s stark is just how much this trend has accelerated as we get closer to implementation of the OECD and G20’s global minimum corporate tax rate (GMCT). The accord was struck in October 2021, targeting a GMCT of 15%.

Though effective for the period commencing 1 January 2024, Ireland’s qualified domestic top-up tax (QDTT) adding an additional 2.5% corporation tax on businesses with revenues of more than EUR 750m is only payable in 2026.

Mergermarket data shows that the numbers of deals involving corporates carving out Irish assets soared in 2023, pausing for breath at still elevated levels in 2024, before spiking further this year.

That acceleration in 2025 coincides with concerns about taxes being compounded by disquiet about tariffs. Carve-out deals can come onto the agenda alongside strategic reviews on the impact of trade policy risk as companies seek to re-engineer their supply chains to secure a more beneficial first point of sale.

Irish-headquartered companies that are overly focused on one territory should consider broader global strategies, McLaughlin said. “There are no one-size-fits-all models, but agility and diversification will be key in a fast-changing environment.”

DCC is an example of an Irish corporate that has run the rule on its corporate perimeter. In April, it announced the sale of its Dublin-based healthcare division to Investindustrial’s Healthco Investment vehicle for an enterprise value of GBP 1.05bn.

The vendor’s CEO, Donal Murphy, described the deal as “a material step in simplifying DCC’s operations and focusing on our high-growth, high-return, energy business.” While DCC has not referenced either tax or tariffs in the context of this disposal, the group has listed changing supply chains, and the potential for geopolitical and trade tensions to create “economic uncertainty” as key strategic risks the group is monitoring.

There have already been 70 carve-out deals worth EUR 3.2bn with Irish targets in the year to date (YTD), according to Mergermarket data. This is the highest YTD deal count in a decade, beating the previous high watermark of 64 transactions in YTD21.

In terms of disclosed deal values, there were 85 carve-outs worth a combined EUR 18.6bn in FY24. This was the only time that this full-year (FY) metric hit double figures in terms of billions of euros this century.

More than half of the disclosed deal value in FY24 came from Ireland’s largest-ever carve-out deal: the sale of a 49% stake in wafers manufacturer Fab 34 from Intel to Apollo. Total deal values in YTD25 have fallen sharply from YTD24 even though the number of deals has risen.

Pan-European trend

A renewed interest in carve-out deals is being seen across Europe as advisors pitch new structures to corporates as a way of navigating macro-economic uncertainties.

The situation is particularly acute in Ireland, where frictionless trade has been a key factor in attracting multinationals, no matter their origins or ownership. However, despite the shock of tariffs, the underlying situation remains largely positive for corporates based in Dublin or elsewhere in the republic.

“Tariff-free trade is just one factor in the Irish success story,” McLaughlin said. “Other factors include high education levels, the English language, a culture that is familiar to investors from the US, the UK and indeed globally, the ability to access the EU, and a favourable tax regime that is part of a stable, business-friendly environment.”

Mobile services – a significant part of the Irish economy – are largely unaffected by tariffs, while the country’s pharma industry is now better positioned to understand the risks. “Relocating pharma platforms can be both complex and costly – especially to the US – so Ireland will likely continue to offer strategic advantages notwithstanding tariffs,” McLaughlin said.

Although the world of trade is changing, it is important for corporates in Ireland to avoid rush decisions.

“Companies should avoid complacency, and cool heads are needed to assess both the risks and the opportunities: it remains early days and we have yet to see the full effect of tariffs,” McLaughlin said. “The world seems to be evolving into more discreet trading blocs, and Ireland remains well-positioned for non-EU companies to access EU markets.”

CRH’s Leviat in focus

Many of the contingency planning exercises are ongoing, McLaughlin said, adding that it is too soon to see deal announcements.

However, Arthur Cox is “continually busy,” he said. “Deals may still be taking longer to close but the pipeline remains good; and we expect to see more private equity activity in the next few months.”

One situation to watch in this context is building materials provider CRH, which has launched the sale of its structural connectors business Leviat. It is being marketed off 2025 EBITDA of GBP 100m.

Meanwhile, foreign-owned corporates that are selling Irish assets include Cathexis Holdings, which appointed Moelis to sell engineering contractor Jones Engineering, according to a report in January; and Encyclis, which is selling a 50% stake in the republic’s largest energy-from-waste plant, as reported earlier this month.

Ireland’s foreign-owned multinationals have already shown themselves to be unsentimental and pragmatic. Where new corporate structures can help them adapt to the new trade paradigm, carve-outs will flow from this strategic repositioning.