Corporation tax in the Republic of Ireland


Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.
Ireland's "headline" corporation tax rate is 12.5%, however, foreign multinationals pay an aggregate of 2.2–4.5% on global profits "shifted" to Ireland, via Ireland's global network of bilateral tax treaties. These lower [|effective tax rates] are achieved by a complex set of Irish base erosion and profit shifting tools which handle the largest BEPS flows in the world.
Ireland's main use "intellectual property" accounting to affect the BEPS movement, which is why almost all foreign multinationals in Ireland are from the industries with substantial IP, namely technology and life sciences.
action in history.
Brad Setser & Cole Frank.
Ireland's GDP is artificially inflated by BEPS accounting flows. This distortion escalated in Q1 2015 when Apple executed the largest BEPS transaction in history, on-shoring $300 billion of non–U.S. IP to Ireland. In 2017, it forced the Central Bank of Ireland to supplement GDP with an alternative measure, modified gross national income, which removes some of the distortions by BEPS tools. Irish GDP was 162% of Irish GNI* in 2017.
s, the largest global Tax Haven in terms of quantum of profits shielded, and the 3rd-largest global Shadow Banking OFC.
Ireland's corporation tax regime is integrated with Ireland's IFSC tax schemes, which give confidential routes out of the Irish corporate tax system to Sink OFC's in Luxembourg. This functionality has made Ireland one of the largest global Conduit OFCs, and the third largest global Shadow Banking OFC.
As a countermeasure to potential exploits by U.S. companies, the U.S. Tax Cuts and Jobs Act of 2017 moves the U.S to a "territorial tax" system. The TJCA's GILTI–FDII–BEAT tax regime has seen U.S. IP–heavy multinationals, forecast 2019 effective tax rates that are similar to those of prior U.S. [|tax inversions] to Ireland. Companies taking advantage of Ireland's corporate tax regime are also threatened by the EU's desire to introduce EU–wide anti-BEPS tool regimes.

Tax system

Tax rates

, there are two rates of corporation tax in the Republic of Ireland:
, the key attributes that tax experts note regarding the Irish corporate tax system are as follows:
The trends in Irish corporation tax receipts to the Irish Exchequer were:
Calendar
Year		Net Corporation
Tax Revenue 		Total Exchequer
Tax Revenue 		as % of Top 10 Payer as
% of Net CT		Foreign Payer as
% of Net CT
Reference
20014.1627.9314.9%——
20024.8029.2916.4%——
20035.1632.1016.1%——
20045.3335.5815.0%——
20055.4939.2514.0%——
20066.6845.5414.7%17%—
20076.3947.2513.5%16%—
20085.0740.7812.4%18%—
20093.9033.0411.8%35%—
20103.9231.7512.4%32%circa 80%
20113.5234.0210.3%39%circa 80%
20124.2236.6511.5%34%circa 80%
20134.2737.8111.3%36%circa 80%
20144.6141.2811.2%37%circa 80%
20156.8745.1315.2%41%circa 80%
20167.3549.0215.0%37%circa 80%
20178.2050.7416.2%39%circa 80%

Structure of Irish taxation

Each year, the Department of Finance is required to produce a report on Estimates for Receipts and Expenditure for the coming year. The table below, is extracted from the "Tax Revenues" section of the report for the prior-year, by which time the "Tax Revenues" for that year are largely known.
The "Tax Revenues" quoted are Exchequer Tax Revenues, and do not include Appropriations-in-Aid items, the largest being Social Security which for 2015 was €10.2 billion, and other smaller items. Irish Personal Income tax, and the two main Irish consumption taxes of VAT and Excise, have consistently been circa 80% of the total Irish Exchequer Tax Revenue, with the balance being Corporate tax.

Low tax economy

Transition in 1987

Ireland's economic model was transformed from a predominantly agricultural-based economy to a knowledge-based economy, when the EU agreed to waive EU State-aid rules to allow Ireland's 'special rate' of 10% for manufacturing, to be extended to the special economic zone called the International Financial Services Centre in Dublin city centre in 1987. The transformation was accelerated when Ireland's standard corporate tax rate was reduced from 40% to 12.5%, in response to the EU's 1996–1998 decision to withdraw the State-aid waiver. The passing of the 1997 Taxes and Consolidated Acts laid the legal foundations for the base erosion and profit shifting tools used by U.S. multinationals in Ireland, to achieve an effective Irish CT rate, or [|ETR], of 0–2.5%.
While low CT rates, are a central part of Irish tax policy, non–CT Taxation in the Republic of Ireland is closer to EU–28 and OECD averages. Ireland's policy is summarised by the OECD's Hierarchy of Taxes pyramid. As shown in, annual Irish CT has been between 10 and 16 percent of annual Total Irish Tax from circa 1994 to 2018. From 2000–2014, Ireland's Total Tax-to-GDP ratio was circa 27–30%, versus the OECD average of 33%. However, since Apple's Irish restructuring artificially inflated Ireland's GDP by 34.3% in 2015, Ireland's Tax-to-GDP ratio had fallen to the bottom of the OECD range at under 23%.
In June 2018, tax academics estimated that Ireland was the largest global tax haven, exceeding the combined flows of the entire Caribbean tax haven system. Tax academics have also showed that being a corporate tax haven has been a prosperous economy strategy for Ireland, and most other havens. However, research also showed that the artificial distortion of Ireland's economic data, and GDP in particular, by BEPS flows, led to a large credit bubble during 2003–2007, and an eventual credit–property–banking crisis in 2008–2013.
Ireland's main foreign multinationals are from periods when their home jurisdiction had a "worldwide tax" system, and since the UK switched to a "territorial tax" system in 2009–12, Ireland has been almost exclusively a U.S. corporate–tax haven. In October 2014, The Guardian quoted Bono, the lead singer of Ireland's U2, as saying that "his country’s tax policies have "brought our country the only prosperity we’ve known"". In April 2016, award-winning Irish writer, Fintan O'Toole labeled Ireland's focus on being a U.S. corporate tax haven as the core economic model, as Ireland's OBI,.

Multinational economy

U.S.–controlled multinationals, either legally based in the U.S. or legally based in Ireland, dominate Ireland's economy. In June 2018, the American Chamber of Commerce estimated the value of U.S. investment in Ireland was €334 billion, which compared to 2017 Irish GNI* of €181.2 billion. In January 2018, Eurostat used 2015 data to show the gross operating surplus of foreign companies in Ireland was almost exclusively from U.S. companies, with the UK was a distant second, and little other foreign firm activity.
In 2016–2017, foreign multinationals, being entirely U.S.–controlled:
The main features regarding foreign multinationals in Ireland are:
Ireland's corporate BEPS tools emphasise job creation. To use Irish BEPS tools, and their ETRs of 0–2.5%, the multinational must meet conditions on the intellectual property they will be using as part of their Irish BEPS tool. This is outlined in the Irish Finance Acts particular to each scheme, but in summary, the multinational must:
The percentage of Irish wages-to-profits required in the "business plan" has never been disclosed, however, commentators imply the Irish wage-roll needs to be circa 2–3% of profits booked in Ireland:
To the extent that the Irish jobs are performing real functions, the cost is not a "employment tax", however, at worst case, the U.S. multinational should incur an aggregate effective Irish corporation tax of 2–6%. Therefore, as shown in, while Irish CT has consistently been between 10 and 15% of Total Irish Tax, the additional employment contribution made by U.S. multinationals in Ireland, has led to strong growth in overall Irish Total Taxes.

Top 50 Irish Corporates

The top 50 Irish companies, ranked by 2017 Irish registered revenues, are as follows:
From the above table:

Multinational tax schemes

Background

The tax schemes used by U.S. multinationals in Ireland are called base erosion and profit shifting tools by tax academics. Whereas Ireland's headline corporation tax rate is 12.5%, Ireland's BEPS tools enable an [|effective tax rate] of 0% to 2.5% to be achieved, depending on which BEPS tool is used.
Ireland has been associated with U.S. multinational profit shifting to avoid taxes since the U.S. IRS produced a list on the 12 January 1981. In February 1994, the U.S. tax academic, James R. Hines Jr. identified Ireland as one of seven "major" tax havens for U.S. multinational profit shifting. During the 2014–2016 EU investigation into Apple's Irish BEPS tools, it was revealed that the Irish Revenue Commissioners had been issuing private rulings on Apple's Double Irish BEPS tools as far back as 1991; and that Apple, Ireland's largest company, had an ETR of less than 1%. In 2014, the EU Commission forced Ireland to close its Double Irish BEPS tool, however, Ireland had replacements in place: the Single Malt, and the Capital Allowances for Intangible Assets .
When Apple closed its hybrid–Double Irish BEPS tool in Q1 2015 and restructured into the CAIA BEPS tool, the Irish Central Statistics Office had to re-state Irish 2015 GDP as Apple's CAIA tool had artificially inflated Irish GDP by 34.4%; an event Paul Krugman christened in July 2016 as Leprechaun economics. Because the Irish CSO delayed the re-statement and redacted normal economic data to protect Apple's identity, it was not until January 2018, that economists could confirm Apple as the source of "leprechaun economics", and that at $300 billion, was the largest BEPS action in history. By February 2017, the distortion of Irish economic data by Irish BEPS tools had grown so large, that the Central Bank of Ireland replaced GDP with Modified GNI; 2017 Irish GNI* is 40% below Irish GDP.
In November 2016, Ireland signed the OECD BEPS Multilateral Instrument to curb global BEPS tools but opted out of Article 12 to protect the Single Malt and CAIA BEPS tools. In March 2018, the Financial Stability Forum showed Ireland's Debt–based BEPS tools made it the 3rd–largest Shadow Banking OFC in the world. In June 2018, tax academics showed Irish IP–based BEPS tools were artificially distorting aggregate EU GDP data, and had artificially inflated the EU–U.S. trade-deficit. In June 2018, tax academics confirmed IP–based BEPS tools had made Ireland the world's largest tax haven, and that the $106 billion of annual corporate profits shielded by Irish BEPS tools, exceeded the BEPS flows of the entire Caribbean tax haven system.

Key features

Intellectual property

Ireland's main BEPS tools use intellectual property to effect the profit shift from the higher-tax locations to Ireland, via royalty payment schemes. To avoid incurring Irish corporation tax on these shifted profits, the BEPS tools either send-on the profits to traditional tax havens via royalty payment schemes, or use intangible capital allowances schemes to write-off the profits against Irish tax. This is the reason why most U.S. multinationals in Ireland are from the two largest IP–industries, namely technology companies and life sciences; or, are specific companies with valuable industrial patents such as Ingersoll-Rand and Eaton Corporation.
Ireland describes its IP–based BEPS tools as being part of its "knowledge economy"; however, U.S. tax academics describe IP as "the leading tax-avoidance vehicle in the world". Despite its small size, Ireland ranks 6th in the 2018 U.S. Global Intellectual Property Center league table of the top 50 global centres for IP–leglislation, and 4th in the important Patents sub-category.
While Ireland's most important BEPS tools are all IP–based, Ireland has other BEPS tools including Transfer Pricing–based BEPS tools, and Debt–based BEPS tools.

"Worldwide Tax" systems

Ireland's IP–based BEPS tools have only attracted material operations from multinationals whose home jurisdiction had a "worldwide tax" system; namely, the U.K pre–2009, and the U.S. pre–2018. Ireland has not attracted material technology or life sciences multinationals, whose home jurisdiction operates a "territorial tax" system. , there are only 6 remaining jurisdictions in the world who operate a "worldwide tax" system, of which Ireland is one.
In 2016, U.S. tax academic, James R. Hines Jr. showed firms from "territorial tax" systems make little use of corporate–tax havens, as their tax code applied lower rates to foreign-sourced profits. Hines, with German tax academics, showed the German tax code charged a CT rate of 5% to the foreign profits of German multinationals. Hines was one of the most-cited sources when the U.S. Council of Economic Advisors advocated switching the U.S. tax code to a "territorial system" in the Tax Cuts and Jobs Act of 2017.
In 2014, the U.S Tax Foundation, reported on how the UK had effectively stopped UK corporates [|inverting to Ireland], by switching the UK corporate tax-code to a "territorial system" over 2009-2012. By 2014, the UK HMRC reported that most of the UK multinationals that had inverted to Ireland had either returned to the UK, or were about to be acquired by U.S. multinationals as part of a U.S. corporate tax inversion to Ireland.

Distortion of GDP

An "artificially inflated GDP-per-capita statistic", is a known feature of tax havens, due to the BEPS flows. In February 2017, Ireland's national accounts became so distorted by BEPS flows that the Central Bank of Ireland replaced Irish GDP with a new economic measure, Irish Modified GNI*. However, in December 2017, Eurostat reported that Modified GNI* did not remove all of the distortions from Irish economic data.
By September 2018, the Irish Central Statistics Office reported that Irish GDP was 162% of Irish GNI*. Irish public indebtedness changes dramatically depending on whether Debt-to-GDP, Debt-to-GNI* or Debt-per-Capita is used; the Debt-per-Capita metric removes all distortion from Irish BEPS tools and implies a level of Irish public-sector indebtedness that is only surpassed by Japan.
The Central Statistics Office revised 2015 GDP higher in 2017, increasing Ireland's 2015 GDP growth rate from 26.3% to 34.4%.

Eurostat show that GNI* is also still distorted by certain BEPS tools, and specifically contract manufacturing, which is a significant activity in Ireland.

IP–based BEPS tools

Double Irish

The earliest recorded versions of the Double Irish BEPS tool are by Apple in the late 1980s; and the EU discovered Irish Revenue rulings on the Double Irish for Apple in 1991. Almost every major U.S. technology and life sciences firm has been associated with the Double Irish. Feargal O'Rourke, PwC tax partner in the IFSC is regarded as its "grand architect". In 2018, tax academics showed the Double Irish shielded $106 billion of mainly U.S. annual corporate profits from both Irish and U.S. taxation in 2015. As the BEPS tool with which U.S. multinationals built up untaxed offshore reserves of circa US$1 trillion from 2004 to 2017, the Double Irish is the largest tax avoidance tool in history. In 2016, when the EU levied a €13 billion fine on Apple, the largest tax fine in history, it covered the period 2004–14, during which Apple paid an Irish ETR of <1% on €110.8 billion in Irish profits. Despite the loss of taxes to the U.S. exchequer, it was the EU Commission that forced Ireland to close the Double Irish from January 2015; with closure to existing users by 2020.

Single Malt

In an October 2013 interview, PwC tax partner Feargal O'Rourke, said that: "the days of the Double Irish tax scheme are numbered". In October 2014, as the EU forced the Irish State to close the Double Irish BEPS tool, the influential U.S. National Tax Journal published an article by Jeffrey L Rubinger and Summer Lepree, showing that Irish based subsidiaries of U.S. corporations could replace the Double Irish arrangement with a new structure. The Irish media picked up the article, but when an Irish MEP notified the then Finance Minister, Michael Noonan, he was told to "Put on the green jersey". A November 2017 report by Christian Aid, titled Impossible Structures, showed how quickly the Single Malt BEPS tool was replacing the Double Irish. The report detailed Microsoft's and Allergen's schemes and extracts from advisers to their clients. In September 2018, The Irish Times revealed that U.S. medical device manufacturer Teleflex, had created a Single Malt scheme in July 2018, and reduced their corporate tax rate to circa 3%; and that the Irish State were keeping the matter, "under consideration".
In November 2018, the Irish Government amended the Ireland–Malta tax treaty to prevent the Single Malt BEPS tool being used between Ireland and Malta. On the same day the closure was announced, LinkedIn in Ireland, identified as a user of the Single Malt tool in 2017, announced in filings that it had sold a major IP asset to its parent, Microsoft. In July 2018, it was disclosed in the Irish financial media that Microsoft were preparing a restructure of their Irish BEPS tools into a CAIA Irish tax structure.

Capital Allowances for Intangible Assets

In June 2009, the Irish State established the Commission on Taxation, to review Ireland's tax regime, and included Feargal O'Rourke. In September 2009, the Commission recommended that the Irish State provide capital allowances for the acquisition of intangible assets, creating the Capital Allowances for Intangible Assets BEPS tool. Whereas the Double Irish and Single Malt BEPS tools enable Ireland to act as a confidential "Conduit OFC" for rerouting untaxed profits to places like Bermuda, the CAIA BEPS tool, enables Ireland to act as the "Sink OFC".
CAIA uses the accepted tax concept of providing capital allowances for the purchase of physical assets. However, Ireland turns it into a BEPS tool by providing the allowances for the purchase of intangible assets, and particularly intellectual property assets; and critically, where the owner of the intangible assets is a "connected party" ; and has valued the assets for the inter-Group transaction using an Irish IFSC accounting firm.
CAIA capitalises the tax shield of the Double Irish, and thus materially increases the distortion of the Irish national accounts. This was shown in July 2016 when the Irish CEO had to restate Irish 2015 GDP by 34.4% due to Apple's Q1 2015 restructure into a CAIA BEPS tool. A June 2018 report by the EU Parliament's GUE–NGL body showed that Apple doubled the Irish corporate tax shield of its CAIA BEPS tool by financing the acquisition of the IP via Jersey. Whereas the Double Irish and Single Malt have an ETR of less than 1%, the ETR of the CAIA BEPS tool ranges from 0% to 2.5% depending on the date on which the CAIA tool was started.

Knowledge Development Box

Ireland created the first OECD–compliant 'Knowledge Development Box', in the 2015 Finance Act, to further support it's intellectual property BEPS toolkit.
The KDB behaves like a CAIA BEPS scheme with a cap of 50%. As with the CAIA BEPS scheme, the KDB is limited to specific "qualifying assets", however, unlike CAIA tool, these are quite narrowly defined by the 2015 Finance Act.
The Irish KDB was created with tight conditions to ensure OECD compliance and thus meets the OECD's "modified Nexus standard" for IP. This has drawn criticism from Irish tax advisory firms who feel that its use is limited to pharmaceutical, and some niche sectors.
It is expected these conditions will be relaxed over time through refinements of the 2015 Finance Act; a route taken by other Irish IP–based BEPS tools:
Irish tax-law firms expect the Irish KDB terms will be brought into alignment with the CAIA BEPS tool terms in the future.

Debt–based BEPS tools

Section 110 SPV

A Section 110 Special Purpose Vehicle is an Irish tax resident company, which qualifies under Section 110 of the 1997 Irish Taxes Consolidation Act, by virtue of restricting itself to only holding "qualifying assets", for a special tax regime that enables the SPV to attain full tax neutrality. It is a major Irish Debt–based BEPS tool.
Section 110 was created to help International Financial Services Centre legal and accounting firms compete for the administration of global securitisation deals. While they pay no Irish taxes, they contribute circa €100 million annually to the Irish economy from fees paid to the IFSC legal and accounting firms. IFSC firms lobbied the Irish State for successive amendments to the Section 110 legislation, so that by 2011, Section 110 had become an Irish Debt–based BEPS tool, for avoiding tax on Irish and international assets.
In 2016, it was discovered that U.S. distressed debt funds used Section 110 SPVs, structured by IFSC professional service firms, to avoid material Irish taxes on domestic Irish activities, while State-backed mezzanine funds were using Section 110 SPVs to lower their clients Irish corporate tax liability. Academic studies in 2017 note that Irish Section 110 SPVs operate in a brass plate fashion with little regulatory oversight from the Irish Revenue or Central Bank of Ireland, and have been attracting funds from undesirable activities.
These abuses were discovered because Section 110 SPVs must file public accounts with the Irish CRO. In 2018 Central Bank of Ireland overhauled the little-used L–QIAIF vehicle, so that is now offers the same tax benefits on Irish assets held via debt as the Section 110 SPV, but without having to file Irish public accounts.

L–QIAIF

The Irish QIAIF regime is exempt from all Irish taxes and duties, and apart from the VCC wrapper, do not have to file public accounts with the Irish CRO. This has made QIAIF an important "backdoor" out of the Irish corporate tax system. The most favoured destination is to Sink OFC Luxembourg, which receives 50% of all outbound Irish foreign direct investment. QIAIFs, with Section 110 SPVs, have made Ireland the 3rd largest Shadow Banking OFC.
When the Section 110 SPV Irish domestic tax avoidance scandals surfaced in late 2016, it was due to Irish financial journalists and Dáil Éireann representatives scrutinising the Irish CRO public accounts of U.S. distressed firms. In November 2016 the Central Bank began to overhaul the L-QIAIF regime. In early 2018, the Central Bank upgraded the L-QIAIF regime so that it could replicate the Section 110 SPV, but without needing to file public CRO accounts. In June 2018, the Central Bank announced that €55 billion of U.S. distressed debt assets had transferred out of Section 110 SPVs.
It is expected that the Irish L–QIAIF will replace the Irish Section 110 SPV as Ireland's main Debt–based BEPS tool for U.S. multinationals in Ireland.
The ability of foreign institutions to use QIAIFs to avoid all Irish taxes on Irish assets has been blamed for the bubble in Dublin commercial property. This risk was highlighted in 2014 when Central Bank of Ireland consulted the European Systemic Risk Board after lobbying to expand the L-QIAIF regime.

TP–based BEPS tools

Ireland's transfer pricing based BEPS tools are mostly related to contract manufacturing. By refusing to implement the 2013 EU Accounting Directive, Ireland enables their TP and IP–based BEPS tools to structure as "unlimited liability companies" which do not have to file public accounts with the Irish CRO. In spite of this, many Irish IP–based BEPS tools are so large that tax academics have been able to separate out their scale from filed group accounts. However, Irish TP–based BEPS tools are smaller, and therefore harder to pick out from a listed multinational's group accounts. In addition, the Irish State, to help obfuscate the activities of the larger and more important IP–based BEPS tools, sometimes present their data as manufacturing data. It is generally regarded that Ireland's main TP–based BEPS tool users are the life sciences manufacturers.

Effective tax rate (ETR)

Background

The headline tax rate is the rate of taxation that is applied to the profits that a tax-code deems to be taxable after deductions. The effective tax rate is the rate of taxation implied by the actual quantum of tax paid versus profits before all deductions are applied. The gap between the Irish corporate headline rate of 12.5%, and the much lower Irish corporate effective rate of 2–4%, is a source of controversy:
The Irish State asserts Ireland's ETR similar to the Irish headline CT rate of 12.5%. This is an important issue as Ireland's BEPS tools, the core of Ireland's, rely on having a global network of full bilateral tax treaties that accept Ireland's BEPS tools; major economies do not sign full bilateral tax treaties with known tax havens. When the EU Commission published their findings on Apple's Irish BEPS tools in 2016, Brazil became the first G–20 economy to blacklist Ireland as a tax haven, and suspended the Brazil–Ireland bilateral tax treaty.
In 2014, Ireland refused to implement the 2013 EU Accounting Directive, and invoked exemptions on reporting holding company structures until 2022, so that multinationals can register as Irish "unlimited liability companies", which do not have to file public accounts with the Irish CRO. However, as most foreign multinationals in Ireland are major U.S. listed companies, tax academics have been able to estimate their Irish ETR from U.S. filings. In addition, the 2014–2016 EU investigation into Apple, Ireland's largest company, produced detail on Apple's Irish ETR from 2004–2014.

Independent research

Notable independent research from 1994 to 2018, has estimated Ireland's overall aggregate effective tax rate for foreign corporates at between 2.2% to 4.5%:

Filed accounts

Over the years, the largest U.S. multinationals in Ireland, who are both Ireland's largest companies and pay most of Ireland's corporation tax, have filed various accounts showing their Irish ETR. As discussed above, because Ireland refused to ratify the 2013 EU Accounting Directive, many of these multinationals have switched to "unlimited liability companies" in Ireland, which do not file accounts; thus the information is only available in a few cases. However, where U.S. multinationals have disclosed Irish financials, they all imply an Irish ETR of less than 1 percent.
Examples are :
Irish BEPS tools are not overtly marketed as brochures showing near-zero effective tax rates would damage Ireland's ability to sign and operate bilateral tax treaties. However, since the Irish financial crisis, some Irish tax law firms in the IFSC produced CAIA brochures openly marketing that its ETR was 2.5%.

Apple investigations

Apple is Ireland's largest company, with Irish 2017 revenues that exceed the combined Irish 2017 revenues of the next 5 largest Irish companies added together. Apple has been in Ireland since at least December 1980, when it opened its first Irish plant in Holyhill, in Cork. Apple's tax strategies with Irish BEPS tools had long been under suspicion by tax academics and investigative journalists.
In May 2013, Apple's Irish tax practices were questioned by a U.S. bipartisan investigation of the Senate Permanent Subcommittee on Investigation. The investigation aimed to examine whether Apple used offshore structures, in conjunction with arrangements, to shift profits from the U.S. to Ireland. Senators Carl Levin and John McCain drew light on what they referred to as a special tax arrangement between Apple and Ireland which allowed Apple to pay a corporate tax rate of less than 2%. The investigation labelled Ireland as the "holy grail of tax avoidance".
In June 2014, the EU Commission launched an investigation into Apple's tax practices in Ireland for the period 2004–2014, whose summary findings were published on 30 August 2016 in a 4–page press release; with a 130–page report, including partially redacted information on Apple's Irish business, published on 30 August 2016.
In July 2020, the European General Court ruled that the EU Commission "did not succeed in showing to the requisite legal standard" that Apple had received tax advantages from Ireland, and overturned the findings against Apple.

Irish State rebuttals

In February 2014, as a result of Bloomberg's Special Investigation and Trinity College Professor Dr. Jim Stewart's ETR calculations, the "architect" of Ireland's Double Irish BEPS tool, PricewaterhouseCoopers tax-partner Feargal O'Rourke, went on RTÉ Radio to state that: "there was a hole the size of the Grand Canyon", in the analysis. O'Rourke also referenced the PricewaterhouseCoopers/World Bank survey that Ireland's ETR was circa 12%.
In December 2014, the Irish Department of Finance, gathered a panel of Irish experts to estimate Irish corporate ETR for the Committee on Finance Public Expenditure. The results, summarised on Section 2 of the report, showed all of the Irish experts, with the exception of Dr. Jim Stewart, agreed with Feargal O'Rourke and PricewaterhouseCoopers:
In August 2016, when the EU Commission published the results of their 2–year detailed investigation of Apple's tax structure in Ireland, showing that Apple's ETR in 2014 was 0.005%, the Irish Revenue Commissioners stated that they: "had collected the full amount of tax that was due from Apple in accordance with the Irish law".
In December 2017, the Department of Finance published a report they commissioned on the Irish corporate tax code by UCC economist, Seamus Coffey. The report estimated that Ireland's effective corporation tax rate for 2015 was 7.2%, based on the Net Operating Surplus Method ; and had fallen from 11.2% in 2008.

Corporate tax inversions

Background

An Irish corporate tax inversion is a strategy in which a foreign multinational corporation acquires or merges with an Irish–based company, then shifts its legal place of incorporation to Ireland to avail itself of Ireland's favourable corporate tax regime. The multinational's majority ownership, effective headquarters and executive management remain in its home jurisdiction. Ireland's corporate tax code has a holding company regime that enables the foreign multinational's new Irish–based legal headquarters, to gain full Irish tax-relief on Irish withholding taxes and payment of dividends from Ireland.
Almost all tax inversions to Ireland have come from the US, and to a lesser degree, the UK. The first US tax inversions to Ireland were Ingersoll Rand and Accenture 2009. As of November 2018, Ireland was the destination for the largest US corporate tax inversion in history, the $81 billion merger of Medtronic and Covidien in 2015. The US tax code's anti-avoidance rules prohibit a US company from creating a new "legal" headquarters in Ireland while its main business is in the US. Until April 2016, the US tax code would only consider the inverted company as foreign, where the inversion was part of an acquisition, and the Irish target was at least 20% of the value of the combined group. Although the Irish target had to be over 40% of the combined group for the inversion to be fully considered as outside of the U.S. tax-code.
Once inverted, the US company can use Irish [|multinational BEPS strategies] to achieve an effective tax rate well below the Irish headline rate of 12.5% on non–U.S. income, and also reduce US taxes on US income. In September 2014, Forbes Magazine quoted research that estimated a US inversion to Ireland reduced the US multinational's aggregate tax rate from above 30% to well below 20%.
In July 2015, The Wall Street Journal noted that Ireland's lower ETR made US multinationals who inverted to Ireland highly acquisitive of other US firms, and listed the post-inversion acquisitions of Activis/Allergan, Endo, Mallinckrodt and Horizon.
In July 2017, the Irish Central Statistics Office warned that tax inversions to Ireland artificially inflated Ireland's GDP data.

U.S. inversions

Share of inversions

, Bloomberg ranks Ireland as the most popular destination for U.S. tax inversions, attracting almost a quarter of the 85 inversions since 1983:

List of inversions

, the table below is the Bloomberg list of the 21 U.S. [|corporate tax inversions] to Ireland. The table also includes some known aborted U.S. tax inversions to Ireland. All of the U.S. multinationals listed below are listed on stock exchanges and the Market Capitalisation is as per 21 November 2018. "Spin-off inversions" and "self-inversions" happen outside of the U.S., and thus do not need an acquisition of an Irish—based corporate to execute the move to Ireland, as per U.S. tax code requirements.

U.S. countermeasures

In April 2016, the Obama administration announced new tax rules to increase the threshold for a U.S. corporate tax inversion to be considered a "foreign company", and thus escape U.S. taxation. The new rules were directly designed to block the proposed $160 billion merger of U.S.–based Pfizer and Irish–based Allergan, which would have been the largest corporate tax inversion in history. The rule changes worked by disregarding acquisitions a target, had made in the 3 years prior to the inversion, in meeting the requirement for the target to be 40% of the merged group.
In December 2017, the Trump administration's U.S. Tax Cuts and Jobs Act overhauled the U.S. tax-code and replicated many of the changes the UK made to their tax-code in 2009–2012 to successfully combat inversions. In particular, the TCJA moved the U.S to a hybrid–"territorial tax" system, reduced the headline rate from 35% to 21% and introduced a new GILTI–FDII–BEAT regime designed to remove incentives for U.S. multinationals to execute corporate tax inversions to Ireland.
In December 2017, U.S technology firm Vantiv, the world's largest payment processing company, confirmed it had abandoned its plan to execute a corporate tax inversion to Ireland. In Q1 2018, Pfizer disclosed that post the TCJA its global tax rate for 2019 would be 17%, similar to the circa 15–16% 2019 tax rate of past U.S. corporate tax inversions to Ireland, Eaton, Allergan, and Medtronic. In March 2018, the Head of Life Sciences in Goldman Sachs, Jami Rubin, stated that: "Now that corporate tax reform has passed, the advantages of being an inverted company are less obvious". In August 2018, U.S. multinational Afilias, who had been headquartered in Ireland since 2001, announced that as a result of the TCJA, it was moving back to the U.S.
, there have been no further U.S. corporate tax inversions to Ireland since the 2016–2017 rule changes by the Obama, and the Trump administrations.

Apple's inversion

Apple's Q1 2015 re-structure of their Irish BEPS tool, is considered by some economists to be a quasi–inversion. Whereas Apple did not relocate its corporate headquarters to Ireland like Pfizer tried to do with Allergan, Apple was able to use the CAIA BEPS tool to legally re-locate $300 billion of IP, equivalent to all of Apple's non–U.S. business, to Ireland. While the Obama administration blocked the proposed $160 billion Pfizer–Allergan tax inversion to Ireland in 2016, Apple completed a much larger transaction in Q1 2015, that remained unknown until January 2018. In July 2018, Irish newspaper The Sunday Business Post reported that Microsoft was planning a similar IP–based quasi–inversion to Ireland, as Apple executed in 2015.

UK inversions

Ireland's largest law firm, Authur Cox, records the move of Experian plc to Ireland in 2006, as the first UK corporate tax inversion to Ireland. Experian was formed in 2006 from the de-merger of UK conglomerate GUS plc, but most of Experian's business was U.S. based.
Between 2007 and 2009, several UK multinationals "re-domiciled" to Ireland: WPP plc, United Business Media plc, Henderson Group plc, Shire plc and Charter plc. Unlike the U.S. tax code, the UK tax-code did not require the inversion to be executed by way of an acquisition of an Irish–based corporate who was at least 20% of the merged group. However, in 2009, the UK Labour government switched to a "territorial tax" system, and over 2009 to 2012, the UK Conservative government introduced a number of other corporate tax reforms including reduction of the UK headline CT rate to 20%, creation of new BEPS tools, and re-structure of "controlled foreign corporation" rules. By 2014, the UK HMRC reported that most of the UK multinationals that had inverted to Ireland had either returned to the UK, or were about to be acquired by U.S. multinationals as part of a U.S. tax inversion.
The UK corporate tax reforms not only reversed many of Irish tax inversions but in 2014, The Wall Street Journal reported that "In U.S. tax inversion Deals, U.K. is now a winner"., the UK had received the 3rd–largest number of U.S. corporate tax inversions in history, only ranking behind Ireland and Bermuda in popularity.
, there have been no further UK corporate tax inversions to Ireland since the 2009–2012 rule changes by the Labour, and the Conservative governments.

Other inversions

Ireland's largest law firm, Authur Cox, records the move of Pentair to Ireland in 2014, as the first Swiss corporate tax inversion to Ireland. However, Pentair was a U.S.–controlled firm that had previously inverted to Switzerland, and moved to Ireland, in 2014 to make it more attractive to a larger U.S. corporate tax inversion, which Emerson Electric attempted in 2016, however the change in the U.S. tax-code, meant that Emmerson decided to abandon the inversion, and instead purchased a division of called Pentair Valves for $3.15 billion; the renaming Pentair group re-domiciled to the UK in 2018.
, outside of U.S. and UK inversions to Ireland, there have been no other recorded corporate tax inversions to Ireland from other jurisdictions.

Corporate tax haven

Ireland as a tax haven

Ireland is labelled a both a corporate tax haven, due to its BEPS tools, and a traditional tax haven, due to QIAIFs. The topic is covered in more detail in Ireland as a tax haven, however, the main facts regarding Ireland's corporate tax haven status are:
Ireland does not appear on the 2017 OECD list of tax havens; only Trinidad and Tobago is on the 2017 OECD list, and no OECD member has ever been listed. Ireland does not appear on the 2017 EU list of 17 tax havens, or the EU's list of 47 "greylist" tax havens; again, no EU-28 country has ever been listed by the EU.

Countermeasures to Ireland

UK countermeasures (2009–2012)

In September 2008, The New York Times reported that "Britain is facing a potential new problem: an exodus of British companies fleeing the tax system". During 2007–2008, several major UK multinationals executed corporate tax inversions to Ireland. During 2009–2012, both the Labour Government and the Conservative Government, overhauled the UK corporate tax code, switching from a "worldwide tax" system to a "territorial tax" system. By 2014, the UK HMRC reported most of the UK firms that inverted to Ireland had returned to the UK, or were about to be acquired by U.S. multinationals as part of a U.S. tax inversion.
, since the UK overhauled its tax code, there have been no inversions of UK firms to Ireland; of the 3 main UK–controlled firms in Ireland :
While national tax policy is excluded from EU treaties, the EU has challenged Ireland's tax code under State-aid legislation. Seamus Coffey's 2016 Review of Ireland's Corporation Tax Code chronicled how the EU withdrew the exemption from State-aid rules for Ireland's special tax rate of 10% in 1996–1998, however, Ireland countered the EU withdrawal by lowering the entire Irish standard rate of corporate tax from 40% to 12.5% over 1996–2003. In October 1994, the Financial Times chronicled how the EU Commission forced the closure of the Double Irish BEPS tool in 2015 on the threat of a full State-aid investigation into Ireland's tax code. However, Ireland won a concession from the EU to allow existing users of the Double Irish to keep using it until 2020, and developed replacement BEPS tools, namely the Single Malt and CAIA BEPS tools. In August 2016, the EU Commission levied the largest corporate tax fine in history, on Apple's Irish Double Irish BEPS tool from 2004–2014, using State-aid rules.
In January 2017, the EU Commissioner for Taxation, Pierre Moscovici, explicitly stated to an Irish State Oireachtas Finance Committee that "Ireland is not a tax haven"; however, in January 2018 Moscovi called Ireland and the Netherlands "tax black holes". In January 2018, Ireland was accused of "tax dumping" by German political leaders.
In March 2018, the EU Commission proposed a "Digital Services Tax", targeted at U.S. technology firms using Irish BEPS tools. The DST is designed to "override" Ireland's BEPS tools and force a minimum level of EU tax on U.S. technology firms. The EU have proposed the DST should be a 3% tax on revenues which would translate into an effective 10–15% tax rate ; it is also expensible against national tax, and so the DST would reduce net Irish tax.
In April 2018, the EU Commission's GDPR rules forced Facebook to move 1.5 billion of the 1.9 billion Facebook accounts hosted in Ireland, back to the U.S. The April 2018 Irish High Court ruling in the Max Schrems EU data-protection case could make Ireland even less attractive to Facebook.
The EU Commission's long-standing desire to introduce a Common Consolidated Corporate Tax Base, would have a more severe effect on Ireland's CT system.

US countermeasures (2016–2018)

The U.S. has had a contradictory approach to Ireland's CT system. U.S. investigations, from the first U.S. IRS study in 1981, up to and including 2013 U.S. McCain–Levin Senate investigations into Apple's tax structures, label Ireland as a "tax haven" for U.S. multinationals. However, it was the EU and not the U.S., that forced Ireland to close its Double Irish BEPS tool in 2015. While the Obama administration supported the McCain–Levin findings on Apple, it came to Apple's defense in 2016 when the EU Commission fined Apple €13 billion for taxes avoided over 2004–2014.
This contradiction is chronicled in "political compromises". The source of the contradiction is ascribed to the findings of U.S. tax academic, James R. Hines Jr.; Hines is the most cited author on tax haven research, and his important 1994 Hines–Rice paper was one of the first to use the term "profit shifting". The 1994 Hines–Rice paper showed that low foreign tax rates ultimately enhance U.S. tax collections. Hines' insight that the U.S. is the largest beneficiary from tax havens was confirmed by others, and dictated U.S. policy towards tax havens, including the 1996 "check-the-box" rules, and U.S. hostility to OECD attempts in curbing Ireland's BEPS tools.
However, by 2014 Ireland had become the leading destination for U.S. corporate tax inversions, and in 2016, the Obama administration decided to move against Ireland's CT system by amending the U.S. tax-code to block the proposed $160 billion Pfizer–Allergan Irish corporate tax inversion, which would have been the largest tax inversion in history.
The most serious threat to Ireland's CT system, and Ireland's economic model came in December 2017 with the passing of the Tax Cuts and Jobs Act by the Trump administration. Parts of the TCJA are specifically targeted at Irish BEPS tools as used by U.S. multinationals in Ireland. The TCJA introduces many of the changes that the UK made to its tax code in 2009-2012, including moving to a "territorial tax" system and reduction of headline rate of tax; the UK changes reversed many of the UK corporate tax inversions to Ireland. However the TCJA goes even further and the GILTI–FDII–BEAT tax regime are a more severe "carrot and stick" to encourage U.S. multinationals to re-locate their substantive operations, back to the U.S.
However, the TCJA is large and complex, and in 2018, tax experts have noted that errors and flaws in the TCJA, could be a "boom for Ireland", over the next few years.

Sustainability of system

The above post–2009 UK, EU and U.S. countermeasures against Ireland's corporate tax system, and by extension Ireland's economic model, have been a cause of concern in Ireland, and even the "architect" of Ireland's BEPS tools, PricewaterhouseCoopers tax-partner, Feargal O'Rourke, has warned on the sustainability of Irish CT revenues.
In December 2017, the Irish Government published a study on the sustainability of its corporate tax system by University College Cork economist Seamus Coffey. Coffey reported that Irish CT revenues were sustainable to 2020, but caveated that given the concentration of CT revenues to a handful of U.S. multinationals, a shock to CT revenues was "inevitable".
In Q2 2018, an IMF country report on Ireland, while noting the significant exposure of Ireland's economy to U.S. corporates, concluded that the TCJA may not be as effective as Washington expects in countering Ireland as a U.S. corporate tax haven. In writing its report, the IMF conducted confidential anonymous interviews with Irish corporate tax experts.
However, in June 2018, the former IMF mission-chief for Ireland Ashoka Mody, who oversaw Ireland's bailout during the 2009–2012 Irish financial crisis, warned that in relation to TCJA:

Historical rates (1994–2018)

The following are the historical rates of Irish corporation tax since 1994.
A 'special rate' of 10% for companies in manufacturing, was introduced in 1980–81, and extended to the financial services in the International Financial Services Centre zone in 1987 ; due to EU decision to withdraw EU State-aid approval in 1996–1998, the special rate was phased-out and ended on 31 December 2003 for new schemes, with expiry for all existing IFSC schemes in 2005, and all existing manufacturing schemes by 2010. To counter the EU's decision to withdraw State-aid approval for Ireland's special rate, the Irish State reduced the Irish standard rate of corporation tax from 40% in 1995, to 12.5% by 2003; splitting the standard rate into trading and non-trading rates in 2000.

History

Ireland's corporate tax code has gone through distinct phases of development, from building a separate identity from the British system, to most distinctively, post the creation of the Irish International Financial Services Centre in 1987, becoming a "low tax" knowledge based multinational economy. This has not been without controversy and complaint from both Ireland's EU partners, and also from the US.

Post-independence under Cumann na nGaedheal

It was only with the acceptance of the Anglo-Irish Treaty by both the Dáil and British House of Commons in 1922 that the mechanisms of a truly independent state begin to emerge in the Irish Free State. In keeping with many other decisions of the newly independent state the Provisional Government and later the Free State government continued with the same practices and policies of the Irish administration with regard to corporate taxation.
This continuation meant that the British system of "corporate profits taxation" in addition to income tax on the profits of firms was kept. The CPT was a relatively new innovation in the United Kingdom and had only been introduced in the years after World War I, and was widely believed at the time to have been a temporary measure. However, the system of firms being taxed firstly through income tax and then through the CPT was to remain until the late seventies and the introduction of Corporation Tax, which combined the income and corporation profits tax in one.
During the years of W. T. Cosgrave's governments, the principal aim with regard to fiscal policy was to reduce expenditure and follow that with similar reductions in taxation. This policy of tax reduction did not extend to the rate of the CPT, but companies did benefit from two particular measures of the Cosgrave government. Firstly, and probably the achievement of which the Cumann na nGaedheal administration was most proud, was the reduction by 50% in the rate of income tax from 6 shillings in the pound to 3 shillings. While this measure benefited all income earners, be they private individuals or incorporated companies, a number of adjustments in the Finance Acts, culminating in 1928, increased the allowance on which firms were not subject to taxation under the CPT. This allowance was increased from £500, the rate at the time of independence, to £10,000 in 1928. This measure was in part to compensate Irish firms for the continuation of the CPT after it has been abolished in the United Kingdom.
A measure which marked the last years of the Cumann na nGaedheal government, and one that was out of kilter with their general free trade policy, but which came primarily as a result of Fianna Fáil pressure over the 'protection' of Irish industry, was the introduction of a higher rate of CPT for foreign firms. This measure survived until 1948, when the Inter-Party government rescinded it, as many countries with which the government was attempting to come to double taxation treaties viewed it as discriminatory.

Fianna Fáil under Éamon de Valera

The near twenty years of Fianna Fáíl government between from 1931 to 1948, cannot be said to have been a time where much effort was expended on changing or analysing the taxation system of corporations. Indeed, only one policy sticks out during those year of Fianna Fáil rule; being the continued reduction in the level of the allowance on which firms were to be exempt from taxation under the CPT, from £10,000 when Cumman na nGaehael left office, to £5,000 in 1932 and finally to £2,500 in 1941. The impact of this can be seen in the increasing importance of CPT as a percentage of government revenue, rising from and less than 1% of tax revenue in the first decade of the Free State to 3.64% in the decade 1942–43 to 1951–52. This increase in revenue from the CPT was due to more firms being in the tax net, as well as the reduction in allowances. The increased tax net can be seen from the fact that between 1932–33 and 1938–39, the number of firms paying CPT increased by over 33%. One other aspect of the Fianna Fáil government which bears all the fingerprints of Seán Lemass, was the 1946 decision to allow mining companies to write off all capital expenditure against tax over five years.

Seán Lemass and an Irish tax system

The period between after the late 1950s and up to the mid-1970s can be viewed as a period of radical change in the evolution of the Irish Corporate Taxations system. The increasing realisation of the government that Ireland would be entering into an age of increasing free trade encouraged a number of reforms of the tax system. By the mid-1970s, a number of amendments, additions and changes had been made to the CPT, these included fifteen-year tax holidays for exporting firms, the decision by the government to allow full depreciation in 1971 and in 1973, and the Section 34 of the Finance Act, which allowed total tax relief in respect of royalties and other income from licenses patented in Ireland.
This period from c.1956 to c.1975, is probably the most influential on the evolution of the Irish corporate tax system and marked the development of an 'Irish' corporate tax system, rather than continuing with a version of the British model.
This period saw the creation of Corporation Tax, which combined the Capital Gains, Income and Corporation Profits Tax that firms previously had to pay. Future changes to the corporate tax system, such as the measures implemented by various governments over the last twenty years can be seen as a continuation of the policies of this period. The introduction in 1981 of the 10% tax on manufacturing was simply the easiest way to adjust to the demands of the EEC to abolish the export relief, which the EEC viewed as discriminatory. With the accession to the EEC, the advantages of this policy became increasingly obvious to both the Irish government and to foreign multi-nationals; by 1982 over 80% of companies who located in Ireland cited the taxation policy as the primary reason they did so.

Charles Haughey low-tax economy (1987–2009)

The Irish International Financial Services Centre was created in Dubin in 1987 by Taoiseach Charles Haughey with an EU approved 10% special economic zone corporate tax rate for global financial firms within its 11-hectare site. The creation of the IFSC is often considered the birth of the Celtic Tiger and the driver of its first phase of growth in the 1990s.
In response to EU pressure to phase out the 10% IFSC rate by the end 2005, the overall Irish corporation tax was reduced to 12.5% on trading income, from 32%, effectively turning the entire Irish country into an IFSC. This gave the second boost to the Celtic Tiger from 2000 up until the Irish economic crisis in 2009.
In the 1998 Budget Finance Minister, Charlie McCreevy introduced the legislation for a new regime of corporation tax that led to the introduction of the 12.5% rate of corporation tax for trading income from 1 January 2003. The legislation was contained in section 71 of the Finance Act 1999 and provided for a phased introduction of the 12.5% rate from 32% for the financial year 1998 to 12.5% commencing from 1 January 2003. A higher rate of corporation tax of 25% was introduced for passive income, income from a foreign trade and some development and mining activities. Manufacturing relief, effectively a 10% rate of corporation tax, was ended on 31 December 2002. For companies that were claiming this relief before 23 July 1998, it would still be available until 31 January 2010. The 10% rate for IFSC activities ended on 31 December 2005 and after this date, these companies moved to the 12.5% rate provided their trade qualified as an Irish trading activity.
The additional passing of the important Irish Taxes Consolidation Act, 1997 by Charlie McCreevy laid the foundation for the new vehicles and structures that would become used by IFSC law and accounting firms to help global multinationals use Ireland as a platform to avoid non-US taxes. These vehicles would become famous as the Double Irish, Single Malt and the Capital Allowances for Intangible Assets tax arrangements. The Act also created the Irish Section 110 SPV, which would make the IFSC the largest securitisation location in the EU.

Post crisis zero-tax economy (2009–2018)

The Irish financial crises created unprecedented forces in the Economy. Irish banks, the largest domestic corporate taxpayers, faced insolvency, while Irish public and private debt-to-GDP metrics approached the highest levels in the OECD. The Irish Government needed foreign capital to re-balance their overleveraged economy. Directly, and indirectly, they amended many Irish corporate tax structures from 2009-2015 to effectively make them "zero-tax" structures for foreign multinationals and foreign investors. The US Bureau of Economic Analysis "effective" Irish CT rate, fell to 2.5%.
They materially expanded the capital allowances for intangible assets scheme in the 2009 Finance Act. This would encourage US multinationals to locate intellectual property assets in Ireland, which would albeit artificially, raise Irish economic statistics to improve Ireland's "headline" Debt-to-GDP metric. They also indirectly, allowed US distressed debt funds to use the Irish Section 110 SPV to enable them to avoid Irish taxes on the circa €100bn of domestic Irish assets they bought from NAMA from 2012-2016.
While these BEPS schemes were successful in capital, they had downsides. US multinational tax schemes lead to large distortions in Irish GNI/GNP/GDP statistics. When Apple "onshored" their ASI subsidiary in January 2015, it caused Irish GDP to rise 26.3% in one quarter. Foreign multinationals were now 80% of corporate taxes, and concentrated in a smaller group. In response, the Government introduced "modified GNI" in 2017, which was circa 40% below 2017 Irish GDP, and a paired back of some BEPS schemes to improve corporation tax sustainability.
Ireland's BEPS tax strategy led it to become labelled as one of the top 5 global conduit OFCs, and has come under attack from the US and the EU. Under pressure from the EU, Ireland closed down the double Irish in 2015, which was described as the largest tax avoidance scheme in history. However, Ireland replaced it with the new single malt system, and an expanded capital allowances scheme. More targeted responses have come in the form of the US 2017 TCJA, and the EU's 2018 impending Digital Services Tax.

External references

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