The financial crisis and its fall-out exposed the egregious securitisation of high-risk home loans and the exploitation of Irish tax loopholes by global vulture funds. A recent deal unveiled by The Currency last week brings back the memories.
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.
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.
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.
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.
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.
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