Full coverage: Multinationals

Through a series of mergers and demergers in the last decade, a global pharmaceutical manufacturer became Irish. To defend itself against a Vat claim, it had to reveal the details of the scheme.

Exchequer returns showed swings of hundreds of millions of euros between 2020 and 2021 following a dispute on emergency stamp duty rules. The exact details of the settlement reached between AbbVie and the tax authority, however, remain secret.

In compliance with the 2020 deadline to end the double Irish scheme, the social media giant’s Dublin office placed its Cayman-resident companies in liquidation. They have now disappeared – except one.

The stocks of tech giants and start-ups alike are taking a beating. Some hire freezes will affect Ireland, but the type of multinationals operating here are least exposed to the crunch – for now.

Growing worldwide profits are sitting in Apple’s subsidiary in Cork, including some frozen pending an appeal in its €13 billion dispute with the EU. The tech giant is leveraging the funds in a new way.

When the Irish treasury subsidiary of an overseas manufacturing group gained €200 million thanks to a loan waiver, the company declared this as non-taxable income. This led to a major test case.

Mallinckrodt, a 155-year-old US pharmaceutical manufacturer, came to Ireland in 2013 to set up an intricate corporate and tax structure. After thousands of legal actions threatened to shut it down, its salvage deal has just cleared an Irish examinership.

The Currency first revealed how the US semiconductor multinational had squeezed through the gap left between the ban on the double Irish and single malt structures. Now we have the full picture of how it works – and how efficiently.

As it continues to grow its Irish data centre and e-commerce operations, the US multinational has revealed the potential it attaches to its fast-expanding “development centre”.

EU ministers have again failed to agree on how to implement the global OECD deal on multinational taxation. The whole project could still be derailed, or at least delayed – and some corporations continue to jump into the gap in the meantime.