Computer chips, video games, aircraft leases: As long as a portion of Irish income can be attributed to intangible assets, multinationals have found creative ways of having it taxed at around 5% in the Mediterranean island.
Perigord, which designs artwork for the life sciences sector, sold a majority stake to Indian giant Tech Mahindra last year for €21 million. It has brought fire power and even more ambition to the business, says Perigord CEO Alan Leamy.
Successive rule changes purported to outlaw the double Irish and single malt tax structures but they left a gap wide open. Here is how Abbott stepped into it to minimise the tax due on profits from Covid-19 and other medical tests.
Months before Covid-19, Abbott Laboratories completed the reorganisation of a rapid diagnostics unit across Ireland and Malta. When this business ballooned, profits trickled through the supposedly closed double Irish loophole.
Like so many technology multinationals, Airbnb ran intellectual property through US and Irish loopholes to minimise its tax bills over the past decade. After failing to convince the IRS its figures were right, the firm is prepared to go to court.
When the Double Irish was shuttered, it was replaced with the Green Jersey and the utilisation of intercompany debt structures. It fits a familiar pattern: when one tax loophole closes, another one is usually prised open.
A New York-listed pharmaceutical multinational is seeking approval from US courts to emerge from a crushing pile of debt and litigation. The next steps will play out in the High Court in Dublin, where the firm is formally registered and owns billions of dollars' worth of intellectual property.
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.
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