Why did Dell, just like countless other US-based multinationals in the past two years, replace its double Irish tax structure with the so-called green jersey and transfer dozens of billions’ worth of intellectual property (IP) to Ireland? We know the answer to this question in theory:  to comply with new legislation banning double Irish schemes where access to IP was charged by a non-tax-resident company; to make use of the capital allowance for intangible assets (CAIA) in Ireland instead; to fund the transaction through intercompany debt funnelling a chunk of profits through low-tax jurisdictions; and to submit whatever profit is left to Ireland’s…

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