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Full coverage: Tax

$25.5bn in revenue, $4bn returned to overseas parents and no tax: One year at Dell in Ireland

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.

Thomas Hubert
23rd Dec, 2021 - 6 min read

Two Christmas directives from Brussels: The 15% corporation tax and an assault on shell companies

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.

Thomas Hubert
22nd Dec, 2021 - 7 min read

Top-ups, carve-outs and shelters: What the 15% tax rules will mean for Microsoft, Intel and Pfizer in Ireland

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.

Thomas Hubert
21st Dec, 2021 - 5 min read

Golden handshakes and Deloitte’s Revenue clash

For eight years, Deloitte incentivised older partners to leave the firm and make way for younger talent. Revenue has gone all the way to the High Court to challenge tax deductions on the retirement scheme.

Francesca Comyn
15th Dec, 2021 - 3 min read

Last month saw a record corporation tax take. It may have seen its peak

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.

Thomas Hubert
3rd Dec, 2021 - 6 min read

One year on, Airbnb pulls intellectual property out of Dublin and posts a $3bn Irish loss

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.

Thomas Hubert
30th Nov, 2021 - 4 min read

More business in Ireland, more tax in the US: Google’s new face in a post-double Irish world

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.

Thomas Hubert
30th Nov, 2021 - 5 min read

Tailoring a green Bermuda: How Twilio continues to mix Irish and Caribbean tax savings

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.

Thomas Hubert
15th Nov, 2021 - 4 min read

Twitter has accumulated €100m in Irish tax credits – but why has it written off the next €1bn?

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.

Thomas Hubert
8th Nov, 2021 - 4 min read

Big accountancy firms have long given money to trainees when they pass professional exams. Revenue say it is now taxable

A major accountancy firm is on the hook for a €1.4 million tax bill after the Tax Appeals Commission ruled that its exam payments to trainees are taxable. Tax expert Eoin O'Shea examines what it means for other firms.

Eoin O'Shea
5th Nov, 2021 - 8 min read
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