Full coverage: Multinationals

By deploying the green jersey tax structure at its EMC and VMware divisions while growing the sales of Dell Products during the pandemic, the US technology multinational has reaped the maximum benefits from its Irish presence.

As promised, the European Commission has moved swiftly to translate the global agreement on a minimum corporation tax rate into EU law. A parallel move to restrict the use of structures like Section 110 companies and limited partnerships was not expected at the same time.

The OECD has published the common rules laid down by participants in this year’s global agreement on the taxation of multinationals. Their implementation at EU level will dictate how much US firms end up paying in Ireland.

Cracks are appearing in the so-called green jersey structure used by multinationals to locate more profits in Ireland. In the meantime, it continues to yield an unprecedented bonanza at a time of intense strain on public finances.

The group now known as Meta is famous in Dublin for the gleaming Grand Canal Dock offices churning €40bn worth of targeted advertising. The 15 companies housed there reveal more about the social media giant’s operations in Ireland.

After Fitbit, Airbnb is the latest Silicon Valley multinational in a matter of days to reveal a reversal of its decision to base intangible assets in Ireland. Covid-19 is the official reason, but tax disclosures raise further questions.

Google’s Dublin subsidiaries may have just posted exceptional once-off Irish tax bills, but the Silicon Valley giant’s strategy is now to split international corporation tax between here and the US – as the Fitbit acquisition shows.

With the end of the double Irish scheme, many US tech firms have cut Caribbean subsidiaries out of their corporate structures to focus their tax advantage on Ireland. One of them has just gone back to Bermuda instead – via Dublin.

By locating intellectual property in Ireland, Twitter was planning to shrink taxable profits for 15 years. Now the social network is not so sure the green jersey scheme is going to deliver.

The US Treasury Secretary visited Dublin on Monday as her country entered the final stretch of a fraught congressional budget debate. Upcoming American legislation implementing the OECD-led global tax agreement is the piece of the puzzle with the most direct impact on multinationals operating in Ireland.