Full coverage: Multinationals

For the past three years, many US tech multinationals have been paying their shareholders more money than they earn. The difference came from Ireland, thanks to tax incentives devised by the Trump administration. That cash is now running out.

So many legal punches have landed on Mallinckrodt that it is facing a knock-out blow at any point. While the disputes engulfing the manufacturer of several controversial drugs unfold in the US, they all link back to the group’s corporate structure and intellectual property vehicles here in Ireland.

Forget the paltry €13 billion under dispute in the state aid case between Ireland, Apple and the EU – the Silicon Valley giant continues to repatriate much bigger cash reserves accumulated here, for the benefit of its ultimate shareholders.

Another day, another multi-billion dollar liquidation of a healthy Irish subsidiary by a multinational. Western Digital has taken advantage of US tax breaks to repatriate profits accumulated over the past 15 years by the popular brand of USB drives.

The volume of assets realised through members’ voluntary liquidations has increased nearly 30-fold during the first five months of this year. Why do so many shareholders agree to shut down their company and walk with the cash?

The consequences of the Apple case continue to reverberate, with the recently renamed NortonLifeLock just one of the multinationals changing their corporate structures. After intellectual property transfers and the liquidation of corporate entities straddling Ireland and Jersey, new filings provide the missing piece of the jigsaw in the US online security giant’s Irish move: the consolidation of its global sales empire in a Dublin business park.

The 2016 state aid decision and yesterday’s court judgment quashing it book-end four years that have seen hundreds of billions worth of intellectual property routed to Ireland. The case has influenced where multinationals locate the source of profits, and this influence is set to continue.

Judges in Luxembourg have found that the European Commission failed to prove Irish tax deals with Apple were illegal. The main reason? Investigators didn’t go far enough in their probing of the Revenue’s “incomplete and occasionally inconsistent” rulings.

Since the crisis began, the Revenue Commissioners have halted audit work, allowed firms to warehouse debt and rolled out the state’s wage subsidy scheme. In an exclusive interview, its chairman Niall Cody talks about Covid-19, multinational tax structures and the Revenue’s battle against tax avoidance.

An Irish subsidiary of professional software multinational Cadence recently disclosed new balance sheet data in routine filings associated with a merger. They showed its assets had just jumped by $4.7 billion.