Every year, Irish subsidiaries of multinationals cancel debt previously contracted from related companies overseas to build up their ever-growing asset base here. As reported on numerous occasions by The Currency, it is typical for US-headquartered groups to lend money to their Irish units to finance the acquisition of manufacturing or data centre equipment, intellectual property – or financial instruments re-routing funds to other operational centres around the world. Then a few years later, the debt is often simply waived, with transactions routinely hitting the billion-dollar mark. Is the resulting gain for the Irish subsidiary a taxable profit? The Revenue Commissioners…

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