Double Irish and Dutch Sandwich – Understanding Tax Havens

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Ireland, a country known for U2 and Guinness, is more known in the business world as a tax haven. Ireland is in the same group as Luxembourg and Bermuda; countries with no physical resources as well as human capital. However they leverage their business regulation in order to attract companies by offering a business friendly environment and low taxation on companies incorporated.

Take Ireland, who has been under the international crosshair for a while due to its “Double Irish” tax law (“Dutch sandwich” in the Netherlands), and no that is not a drink. This little loophole is the reason Apple paid an astounding 2% on its profits in Ireland where the corporate tax rate is 12.5%. The key to the law is the fact that parent companies and subsidiaries are separate legal and tax entities.

If companies were able to move goods and services around in an arm’s length way between each other, wouldn’t it be good to channel the profits towards a country with a low or 0% tax rate.

For example, imagine subsidiary X in Ireland and Manager Y that controls it in tax haven Bermuda. Every time the subsidiary makes a profit it gets transferred to Y. Therefore it gets taxed less or not at all – since that profit counts as Manager Y’s profits. Since there is no need to repatriate the capital back into the US, this results in a low single tax rate. Had the subsidiary been based in a country such as the US, that same subsidiary would like be facing a tax bill in the 40% range. This explains the large cash position that Apple has overseas, much more than the cash position in the US.

Of course, not every company can take advantage of this double Irish loophole. The rules benefit mostly technology and pharmaceutical companies. Why? Because these companies own intellectual property. Why is that important? In transferring the profits from subsidiary X to Y, the company require a “legitimate” reason to pay Y. Even the rules state that companies cannot simply transfer profits from Ireland to a low tax haven for the sole purpose of paying lower taxes. The loophole around the legislation is to come up with a legitimate reason for having to pay Manager Y in Bermuda.

Thus the strategy is to have Manager Y own the intellectual property and then a “royalty” contract is established between X and Y. In this way, subsidiary X sends the royalty to Y thereby counting as Y’s profit and a cost to X.

Fortunately, diamonds are forever but tax havens are not. In 2015, Ireland reversed the Double Irish tax law and now requires companies incorporated in Ireland to be tax residents in Ireland. For companies who incorporated prior to the ruling they will get an extra 5 years of the benefits of the law until 2020. Nonetheless, this does not mean the end to an era for these companies since the corporate tax rate in Ireland is still 4 times less than that of the US. Google says they remain committed to Ireland.

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Source by Jeff Kaminker

Dublin – The City of Diversity

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Ireland is an island in every sense of the word. It is located between Europe and the US. It has managed to sustain more of the American and the European culture, than neighboring Britain. Dublin’s airport is surprisingly small for being the center of a developed economy. It is the American bridge to Europe and a home to the largest low-budget carrier of the old continent- the “Ryanair”.

You will find the spirit of Ireland within the contrast of it’s cities. And Dublin is a city of contrasts indeed – the contrast between the 7th financial center of Europe and the town of low buildings with brick facades in the XVIII century style; between the surprisingly calm center with it’s hiking areas and the enormous traffic jams; between the carefree, casual look of the people on the streets during a certain time of the day and the prices in the establishments, which is close to a normal Bulgarian salary. At the crossroads of global business, Ireland has defined itself as the most globalized country in the world. I found that the romantic idea of the Green Island still thrives unspoiled among the French and Australian wines, Polish and Chinese workers,American SUV-s, Burger King and plasma TV.

I arrived with the belief that Ireland is all about U2, dancing, and bad weather. Since Bono apparently rarely drops by the country, Irish dancing is certainly not a popular activity in the pubs, and I didn’t see any rain, I was pleased to discover just how fun it was to explore Dublin. From my Dublin apartment window I saw several large posters that invited for the exhibition of William Yates. While passing by them, I thought of the justification of the Royal Academy of Sweden, where the poet was awarded the Nobel Prize for Literature in 1926: For his truly inspired poetry, which essentially depicts the spirit of an entire nation.

How does one actually depict the spirit of a nation, that for half a century has had not one, but four literary Nobel Prize winners? Mathematically speaking, this means that for every one million of the Irish, there is at least one man that is a brilliant writer. Maybe this is precisely what makes Dublin a little more special than any other city in the world. In the days that I spent there, I went past two of the houses of Oscar Wilde, a couple more of James Joyce’s (as it appears, their number is endless).

I also found a sculpture exhibition dedicated to Bernard Shaw. It was part of a literary fest under the name of “Samuel Beckett”, covering a poster of the forthcoming show of Sinead O’Conner at a local club. Add to that the Monument of Wellington – the hero that defeated Napoleon.

The weather on the island is wet for most of the time. It is not too difficult to figure out why there is a place in the city, where one can find most of the popular pubs. Briefly speaking, the true Irish pub obviously represents a small place without enough seats, unlimited supply of beer, nice music in the background and a TV with “sky sports” on.

In Dublin, for example, there are more than 1000 pubs. And the “Temple Bar” is one that is definitely worth the visit.

The central area of Dublin is composed almost entirely of bars and pubs, ready to welcome you at any time of the day. For example there are 4 pubs next to my holiday apartment in Dublin. Besides its obvious advantages – a place which has more beer taps than visitors – Temple Bar is also near the pedestrian commercial area of Dublin. An area that is quite worth the straw, although the souvenirs’ prices are sinfully high.

If your passion is not shopping, but is instead education, history and sight seeings, you will definitely not be disappointed.

Here you will find the most famous university on the island – the Trinity College. There are several cathedrals(in one of which are kept the British military flags of the Crimean war).

The garden behind the parliament houses the National Gallery, the National Museum and the Natural Museum. In fact, the latter is just a small, old building, with a stunning collection of animals inside. Hanging from the ceiling, there is a huge whale skeleton. You will also find all kinds of animals- from the giraffes and rhinos to the small African insects. The whole heritage of the Irish zoologists, who traveled around the world is there.

On the corner of the same street, which I recognized from a U2 video, I found the home of Oscar Wilde. There was just a humble sign before it. When I looked further in the garden, I stumbled upon a gorgeous statue of Wilde himself, resting upon a stone, grinning flippantly at me.

I took my time to pay the honor in the memory of one of the most famous world writers.

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Source by Mike Lock

History and Origins of the Celtic Cross

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The Celtic cross is a cross whose four “arms” are intersected by a central, circular ring – a function of both structural form and symbolism. While the roots of the Celtic Cross are likely in Paganism with the ring symbolizing the sun and “renewal,” it has become a potent symbol of Christianity and Irish heritage. The roots of the Celtic Cross can be traced back to Prehistoric Europe where the “sun cross” – a circle with an “x” or cross shape scratched inside began to appear on cave drawings and burial sites. The image persisted through the Bronze and Iron ages evolving into the Celtic Cross. It’s likely that the “cross” symbolized North, South, East and West.

Irish folklore tells the story of how Saint Patrick combined the Christian Cross with the “sun” to emphasize the importance of the cross to the Pagan followers, giving birth to the Celtic Cross. Though there is likely little truth to the tale. Around the 7th Century, Irish monks in the Celtic regions of Ireland and Great Britain began to erect upright or “high” crosses, many incorporating the Celtic Cross’ characteristic ringed structure. Many of these crosses survive today in Cornwall, Wales and on the island of Iona along with many others in Ireland.

Early Celtic Crosses often bore zoomorphic, or animal imagery, carved in the stone due to the influence of the animal style common in the Iron age. Not surprising given that warrior-herdsmen were so dependent on wildlife for food and clothing. This influence died off after the Iron Age as art in Ireland and Britain moved into the “Insular Period.” Artists during the Insular Art period produced many Celtic Crosses throughout Ireland, Wales and Scotland in the Hiberno-Saxon style. The “Insular Art” movement takes its name from the Latin word “Insula” which means “island.” This applied to the Isles of Britain and Ireland, and spoke to the shared nature of the artwork between the two regions that were vastly different than what was being produced throughout the rest of Europe. The Celtic crosses of this time were ornate and often bore spiraling geometric patterns that likely symbolized man’s “twisting” journey through life.

Around the 15th century, interest in the Celtic Cross and its influence as an art form waned. In the mid-19th century, a Celtic Revivial began that resulted in increased display and use of Celtic crosses in Ireland. The Celtic cross became fashionable as a cemetery marker in Victorian Dublin around the 1860s. This revival continued to spread across the whole of Irland and beyond and the symbol began to take on importance as a symbol of Irish heritage in addition to its religious conotation.

Today, the Celtic cross is commonly used as a gravemarker, though this is a departure from both medieval and Celtic revival periods when the symbol was used mainly as a monument and had little association with grave markings. The imagery of the Celtic cross has expanded its influence even in modern times, often spotted in jewelry as an expression of Irish pride and Christianity. The symbol is also seen in everything from T-shirts to tattoos. The Northern Ireland national football team use the Celtic Cross imagery in their logo and branding. The symbol has had some unfortunate attention as well and was recently banned from display in Germany when a prohibited neo-Nazi party co-opted the image as a symbol of their movement.

Famous Celtic Crosses that can still be seen today are at the Cross of Kells, County Meath, Ireland; Ardboe Auld Cross, Ardboe, County Tyrone, Northern Ireland; the crosses at Monasterboice, County Louth, Ireland; and the Cross of the Scriptures, Clonmacnoise, Ireland.

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Source by Rob Mabry

TV3 Now Available on the Ireland’s New SaorView DTT Service

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DTT Channel Lineup

TV3 have joined Ireland’s Digital Terrestrial TV (DTT) revolution and have joined Saorview lineup. The channels now on the system include

  • RTE1
  • RTE2
  • TV3
  • TG4
  • RTE News
  • RTENL2 (test transmissions only)

What does this mean for you?

Finally for those living in Terrestrial TV land there is a full digital alternative to the existing analogue. Along with the 4 Irish you can also get the pretty excellent RTE News channels. So for those who like their TV free from bills and static interference this is by all accounts a good day. Those of us who have been following this story over the last year will know that TV3 had been DTT service last year and then went off so hopefully this time it is for real

How do I tune TV3 into my DTT receiver or MPEG4 TV?

You don’t need to do anything it will come in automatically where the old RTENL1 signal was. If you rescan this signal is now called TV3

How Can I get the DTT service?

To receive Digital Terrestrial TV you will need a UHF Aerial kit & some type of DTT receiver

You have 3 basic choices in terms of receivers

  • Buy an MPEG4 TV – this way you don’t need a buy a receiver
  • Buy a DTT receiver such as the TRIAX TR110 DTT Receiver which is SD but full HD DTT Receivers should be available shortly.
  • Buy a combo Satellite & DTT receiver such as the Edision Argus 2in1 receiver – which gives the 5 Irish channels, BBCs, ITVs etc on a single box

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Source by Barry F

Doolin, County Clare, Ireland – The Perfect Location For A Family Getaway

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Need to get out of the fast lane for a few days? Doolin located in country Clare, close to the world renowned Burren, is a fantastic place to visit. Better still there’s lots to do. This article describes just a few of the many attractions in the area.

The Burren: The name Burren comes from the Irish word “Bhuireann” which means a stoney place. Stoney it certainly is: 300 sq. kilometres of limestone covered countryside. However, it is not as desolate as it sounds. Rare Mediterranean and Alpine plants flourish side by side. A guided tour is a must. Unless you are a botanist, you will be astounded by its rocky beauty but without a guide you’ll miss the incredible flora. If you’re feeling energetic there are many mapped walks across the Burren.

Aillwee Cave: if you have children you should visit Aillwee cave. Jack McCann a local man originally discovered the cave and investigated it by candlelight. However, Jack kept his find secret for decades and only showed the cave to others in the 1970’s. The cave was opened to the public in 1976 and extends for at least 1 km underground. This hugely impressive cave contains waterfalls, stalagmites, stalactites, brown bear bones and lots more. Surrounded by a forest walk with a restaurant on site, it’s a half days entertainment in itself.

Cliffs of Moher: The cliffs of Moher tower over 200 metres above the Atlantic Ocean. There’s a new visitor centre with an excellent Cliffs of Moher interpretive display –“Atlantic Edge”. The virtual reality cliff face show – “The Ledge” – should not be missed. After that a walk along the cliff edge gives outstanding views of the cliffs and Atlantic. Don’t worry it’s walled and safe for kids.

Cliffs of Moher boat trip: drive to Doolin pier and you can book a boat trip to the base of the Cliffs of Moher. Once there you cannot but be amazed at the sheer size and rugged beauty of the cliffs. The tourists on top of the cliffs are but distant specs and you can get a close up view of the bird population of Atlantic Puffins, Gulls, Guillemots, Shags, Ravens and Choughs. You can also book trips to the nearby Aran Islands from Doolin pier. These trips range from a ½ a day to an overnight stay.

Doolin pubs: The pubs of Doolin have been a breeding ground for world renowned traditional Irish musicians. There are three traditional pubs McGanns, O’Connors and McDermotts in Doolin. All have lots of traditional music and home cooked food. Kids are allowed until 9:00pm.

The Burren Perfumery: a most interesting visit with all the flowers and herbs that form the basis of the perfumes and soaps locally sourced on the Burren. There’s a small tea room and herb garden.

The Burren Interpretive Centre, Kilfenora: there’s an excellent “walk through time” Burren exhibit, a video, craft centre and tea room.

A visit to Lahinch beach on a summers day is reminiscent of Hawaii with surf schools the length of the beach.

Liscannor Stone and Rick Shop: full of precious stones, semi precious stone, local stone and lots and lots of prehistoric fossils. As you drive back from one of the other many attractions in the area you can just call in to have look! But beware you’ll probably emerge with a 10,000 year old fossil souvenir!

The best thing about all of these attractions is that none is more than a half an hour drive from Doolin. Doolin can be very busy in the summer but it’s great place to visit and lots to do. You could consider a few days away outside the bustling summer season and if you are lucky enough to get good weather a great time is guaranteed.

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Source by James Cahill

Simply Dublin

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Tours in Dublin Ireland delights you with their offerings of a superb selection of tourist attractions and places to visit. Castles, museums, art galleries, zoos and theme parks are the varied places one can visit in Dublin.

Dublin Castle is one of the attractions where you will find the statue of justice standing above the main entrance archway. You may be lucky to get a glimpse of the inaugurations of the Presidents of Ireland. There is a fee for admission to the castle which opens on weekdays from 10 am to 5 pm and from 2 pm to 5 pm on Saturday and Sunday.

A visit to the Dublin Zoo, situated in 30 acres of ground in Phoenix Park is a treat to animal lovers. It is home to almost 700 animals and tropical birds. If you like you can participate in the ‘Meet the Keeper’ as well as a feeding program held daily. The interesting aspect of a visit to the Dublin Zoo is a train ride around the Zoo.

Most tourists visit ‘The Garden of Remembrance” as a mark of respect to those who laid down their lives fighting for the struggle of Irish independence. It was established on the 50th anniversary of the 1916 Easter Rising to remember those freedom fighters who died during the course of struggle for Irish Independence. Admission is without any charges and it remains open from 8.30am to 7.30 pm, Monday to Saturday. On Sundays it is open from 10am to 6pm.

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Source by Vivek Kuriyal

The Battle of Clontarf

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The Battle of Clontarf took place outside the town of Dublin on Good Friday, 1014. On one side Brian Boru led the Irish in the resistance against the Vikings of Dublin who were supported by Vikings from England, Scotland, the Isle of Man, France and Orkney Islands.

Born around 940, Brian Boru was an inhabitant of Co Clare, and belonged to the Royal house of Thomond. At this point in Ireland’s history, Viking invaders had dominated the island. From an early age Brian led his followers against the Vikings, who at that time ruled large coastal areas around Ireland. He vanquished them in several battles and ultimately succeeded in clearing the Vikings from Munster. After his older brother, Mahon, was murdered in 976, Brian Boru became King of Munster. In 1002 he became King of Ireland and his main goal from then on was to clear the Vikings from the whole country.

Finally in the Battle of Clontarf the Vikings of Ireland were defeated. The Irish losses were estimated to be 4,000 including their king and most of his sons, however of the 7,000 to 8,000 Vikings and allied forces, an estimated 6,000, including almost all the leaders, were killed.

At the end of the battle, the Viking forces withdrew to their ships. During this retreat the Irish combatants were negligent leaving Brian’s tent unprotected and a group of fleeing Danes and their leader Brodir slayed him with an axe whilst he was kneeling in prayer.

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Source by Colm B Brady

Things to Do in Cork, Ireland

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Cork is a county located in the south of Ireland and is the largest county in Ireland. Even though it is the largest county in Ireland, it is not the capital city as Dublin takes that reign.

You can find many places to visit and things to do in Cork. You may of heard of the Blarney Stone which is located in County Cork, it is said that when you kiss the Blarney Stone, you will receive the gift of the gab.

Fota wildlife Park is also located County Cork, this is a large park where animals are allowed to freely roam so that they can be enjoyed by all of the family.

Patrick Street is the main street in Cork city and is filled with clothes shops, coffee shops, boutique shops and much more. You may enjoy a visit to the english market for some fresh seafood or fruit. This market is one of the most famous markets in Cork and a visit is highly recommended.

If you are lucky enough to be in Cork city while the Cork hurling or football team are playing in a championship game, you should definitely think about visiting Pairc Ui Chaoimh which is the stadium where Cork play their GAA games. It is located along side the River Lee which is the main river that runs through Cork City.

If you have some time to spare while visiting Cork, you should consider visiting Mizen Head which is the most southerly point in Ireland and boasts some fantastic views. It is however a long drive, from Dublin to Cork takes approximately 2 hours and then you will find that to drive deep into West Cork to visit Mizen Head may take another 3 hours. Take caution when using these roads as they are very narrow and windy and are also poorly maintained.

If you are after visiting Cork during the summer time and are looking to hit the beaches, then you are in luck as Cork is known as the sunny south east. Look for directions to Youghal, Co.Cork and you will find many beaches including a beach located in Youghal town itself which is a small fishing town. If you visit Youghal in late July or early August, bring your fishing rod and you may be in for a large catch of mackerel of the pier in Youghal.

There is a range of hotels in Cork to stay in while you are visiting and you will also find many cheap Cork hotels ranging in price from €40 to €100 if you are looking for Cork hotel.

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Source by Ronan Carr

St. Patrick’s Day: It’s Paddy, Not Patty!

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It’s been maybe 10 and a half years since I last celebrated St. Patrick’s Day in Ireland and through travelling around this fine world, I’ve had this conversation too many times to count:

Someone: ‘Where are you from?’

Me: ‘Ireland.’

Someone: ‘Oh, you’re Irish! Me too.’

Me: ‘Really? What part of Ireland are you from?’

Someone: ‘Oh, I’ve never actually been to Ireland. My great-grandmother was Irish.’

Me: ‘So where in America are you from?’

There’s no day in the whole year that this conversation happens more than on March 17th… or the Saturday after if it falls on a weekday. There’s also the whole rigmarole of me also having to prove I’m Irish on occasion due the fact that six years in England and four in Korea has led to my accent being a bit askew. Also living with a Canadian boy I’ve pick up little bits of twang… although he doesn’t say ‘aboot’ or ‘ey’ nearly as much as I would have hoped.

Just while I’m on the subject of words said differently, please please Americans (and all other people in the world who do it) stop calling it St. Patty’s Day. It’s St. Patrick’s Day, St. Paddy’s Day or just Paddy’s Day. Under NO circumstances should it be called St. Patty’s Day.

Ever.

At all.

Paddy: Short for Patrick.

Patty: Short for Patricia, the name of Marge’s sister in The Simpsons and the name of a small, round serving of meat usually found on a burger. Can be used to cover everything from the dubious stuff that goes on a McDonald’s Cheeseburger to the gourmet homemade thingys my boyfriend makes.

If you don’t believe me, go to Ireland, call a fella ‘Patty’ and see what happens, I dare ya. It’s worth knowing, Ireland’s healthcare costs are astronomical so ye may want to pick a guy you’ve got a fightin’ chance with.

Moving on. Now, not a lot is known about old St. Paddy himself. What is known is that he wasn’t Irish. At all. Not one little bit. He’s British.

Just to recap our geography, before anyone writes and says, ‘it’s the saaaaame’, Britain = England, Scotland and Wales. Not Ireland.

St. Patrick, presumably back when he was just plain Patrick (or Paddy to his friends), at age sixteen was kidnapped by Irish raiders and brought to Ireland to work as a shepard. I kid you not, we properly snatched and grabbed him.Then we kept him for 6 years until he escaped and fled back to his family in Britain.

The story goes, as stories do, that while alone and secluded from other people working on the mountains in Ireland, God spoke to him. God told him he’d soon be free and it was time to leave Ireland. Upon his return to his homeland, he entered the church where he stayed for 15 years (approx, who really knows) and then he returned to Ireland. Seriously, he came back to the people that kidnapped him in the first place.

Now widely (blamed for?) credited with bringing Christianity to our small little island (was it really necessary?), we celebrate St. Patrick’s death in the form of drinking, parades with floats, green beer, dying our rivers green (with orange dye no less) and wearing silly hats.

Do you think this is what he had in mind when he brought us religion? Floats and alcohol? One can only hope!

So where does the shamrock come into all this?, I hear you wondering.

Well, St. Patrick used the shamrock (a three-leafed clover, NOT four, three… THREE) to explain the Holy Trinity to the people of Ireland and naturally, we adopted as our national flower.

Ah, tell me about the snakes.

Apparently St. Patrick, in his spare time between praying, talking to God, explaining the Holy Trinity to people and spreading the Christian word, also got rid of all the snakes in Ireland. Every single one of them. No snakes in Ireland no more. And why? Cos St. Paddy got rid of them all. True story. Probably. Again, who really knows?

And what about the leprechauns?

They don’t come into this story so we’ll have to deal with them at a different time.

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Source by Jenny Maxwell

Distance Learning in Ireland

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There are several questions that need to be asked when thinking of doing a distance learning course in Ireland.

What type of qualification will I get?

Distance Learning through a recognised education provider generally works on a modular basis. This means that for every module or section of a course you study, you receive credits. Once you have achieved a sufficient amount of credits you will be awarded a Certificate, Diploma or Degree. The level of qualification you achieve and the length of time it takes is up to you. You could work towards a degree over 3 or 4 years, or simply study subjects that appeal to you on a more leisurely basis.

Distance Learning Providers

Since Adult Education has become a booming business in Ireland, there are now more Distance Learning colleges and courses available than ever before. Some of the more mainstream providers are as follows:

The Open University

Probably the best known, and for a long time the only provider of Distance Learning, the Open University offers over 600 courses in a variety of areas. Recognised worldwide, courses are available in a variety of fields from Humanities to Engineering.

Oscail

Perhaps the Irish version of the Open University but on a much smaller scale, Oscail was set up and is accredited by Dublin City University. They currently offer diplomas and degrees in Nursing, Arts, Science and IT, in addition to some post graduate options.

Universities

Many Universities now offer some Distance Learning options as part of their adult learning programmes. NUIG for example, offers a Diploma/Degree in Social Care (amongst others), while the National College or Ireland, offers a Degree in Human Resource Management. If there is a specific course you are interested in, your local University is often a good first port of call.

Private Colleges

There are a number private learning colleges in Ireland, offering a whole range of courses and options. Some like the College of Progressive Education are specialised in the type of courses they offer (Childcare/Montessori), while others such as Kilroy’s College offer a much wider range of options.

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Source by J. O Clarke