Full coverage: Multinationals

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.

The Exchequer collected a record amount of corporation tax last year. The US software giant was the largest contributor (that we know of), according to new analysis of 13 related companies incorporated and domiciled by the group in Ireland. 

As The Currency revealed that several multinationals continue to use the double Irish tax structure via Malta, domestic retailers EuroGiant and Anthony Nicholas demonstrated that success is achievable without such tactics – they just focused on strengthening their balance sheet.

Over the past eight years, the US and Irish governments have tried and failed to close tax loopholes on three occasions. Why is this, and can the collective approach under the new OECD deal turn the tide?