Like many multinationals, Accenture holds intellectual property (IP) assets in an Irish subsidiary that receives royalties from other group companies as they use its technology to sell services to customers around the world. Some countries levy withholding taxes on such royalties, which are deducted from the corresponding payments made to the Irish company, Accenture Global Solutions Limited. The treatment of this foreign withholding tax for the calculation of the company’s corporation tax liability in Ireland has been disputed for the past five years. The High Court has now decided the case, which has implications for all multinationals using Ireland as…

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