The “Irish-shoring” of intellectual property (IP), as US economist Brad Setser puts it, has seen many multinationals move multi-billion-dollar intangible assets like technology and brand rights to this country in recent years.  The resulting so-called green jersey corporate structures have dramatically expanded both the size and volatility of Irish corporation tax receipts as the large and risky slice of profits derived from this IP became taxable in Ireland, rather than in zero-tax Caribbean jurisdictions under the double Irish scheme phased out between 2015 and 2020. This is the theory, and the general rule. There are, however, exceptions. Dell, the US-headquartered…

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