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Ireland as a tax haven
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Ireland as a tax haven
Ireland has been labelled as a corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic tax haven lists, including the § Leaders in tax haven research, and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.
Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates § Effective tax rates of 0% to 2.5% on global profits re-routed to Ireland via their tax treaty network. Ireland's aggregate § Effective tax rates for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit. Ireland's tax-free QIAIF & L–QIAIF regimes, and Section 110 SPVs, enable foreign investors to avoid Irish taxes on Irish assets, and can be combined with Irish BEPS tools to create confidential routes out of the Irish corporate tax system. As these structures are OECD–whitelisted, Ireland's laws and regulations allow the use of data protection and data privacy provisions, and opt-outs from filing of public accounts, to obscure their effects. There is arguable evidence that Ireland acts as a § Captured state, fostering tax strategies.
Ireland's situation is attributed to § Political compromises arising from the historical U.S. "worldwide" corporate tax system, which has made U.S. multinationals the largest users of tax havens, and BEPS tools, in the world. The U.S. Tax Cuts and Jobs Act of 2017 ("TCJA"), and move to a hybrid "territorial" tax system, removed the need for some of these compromises. In 2018, IP–heavy S&P500 multinationals guided similar post-TCJA effective tax rates, whether they are legally based in the U.S. (e.g. Pfizer), or Ireland (e.g. Medtronic). While TCJA neutralised some Irish BEPS tools, it enhanced others (e.g. Apple's "CAIA"). A reliance on U.S. corporates (80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add), is a concern in Ireland.
Ireland's weakness in attracting corporates from "territorial" tax systems (Table 1), was apparent in its failure to attract material financial services jobs moving due to Brexit (e.g. no US investment banks or material financial services franchise). Ireland's diversification into full tax haven tools (e.g. QIAIF, L–QIAIF, and ICAV), has seen tax-law firms, and offshore magic circle firms, set up Irish offices to handle Brexit-driven tax restructuring. These tools made Ireland the world's 3rd largest Shadow Banking OFC, and 5th largest Conduit OFC.
Ireland has been associated with the term "tax haven" since the U.S. IRS produced a list on the 12 January 1981. Ireland has been a consistent feature on almost every non-governmental tax haven list from Hines in February 1994, to Zucman in June 2018 (and each one in-between). However, Ireland has never been considered a tax haven by either the OECD or the EU Commission. These two contrasting facts are used by various sides, to allegedly prove or disprove that Ireland is a tax haven, and much of the detail in-between is discarded, some of which can explain the EU and OCED's position. Confusing scenarios have emerged, for example:
The next sections chronicle the detail regarding Ireland's label as a tax haven (most cited Sources and Evidence), and detail regarding the Irish State's official Rebuttals of the label (both technical and non-technical). The final section chronicles the academic research on the drivers of U.S., EU, and OCED, decision making regarding Ireland.
Ireland has been labelled a tax haven, or a corporate tax haven (or Conduit OFC), by:
Ireland has also been labelled related terms to being a tax haven:
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Ireland as a tax haven
Ireland has been labelled as a corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic tax haven lists, including the § Leaders in tax haven research, and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.
Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates § Effective tax rates of 0% to 2.5% on global profits re-routed to Ireland via their tax treaty network. Ireland's aggregate § Effective tax rates for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit. Ireland's tax-free QIAIF & L–QIAIF regimes, and Section 110 SPVs, enable foreign investors to avoid Irish taxes on Irish assets, and can be combined with Irish BEPS tools to create confidential routes out of the Irish corporate tax system. As these structures are OECD–whitelisted, Ireland's laws and regulations allow the use of data protection and data privacy provisions, and opt-outs from filing of public accounts, to obscure their effects. There is arguable evidence that Ireland acts as a § Captured state, fostering tax strategies.
Ireland's situation is attributed to § Political compromises arising from the historical U.S. "worldwide" corporate tax system, which has made U.S. multinationals the largest users of tax havens, and BEPS tools, in the world. The U.S. Tax Cuts and Jobs Act of 2017 ("TCJA"), and move to a hybrid "territorial" tax system, removed the need for some of these compromises. In 2018, IP–heavy S&P500 multinationals guided similar post-TCJA effective tax rates, whether they are legally based in the U.S. (e.g. Pfizer), or Ireland (e.g. Medtronic). While TCJA neutralised some Irish BEPS tools, it enhanced others (e.g. Apple's "CAIA"). A reliance on U.S. corporates (80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add), is a concern in Ireland.
Ireland's weakness in attracting corporates from "territorial" tax systems (Table 1), was apparent in its failure to attract material financial services jobs moving due to Brexit (e.g. no US investment banks or material financial services franchise). Ireland's diversification into full tax haven tools (e.g. QIAIF, L–QIAIF, and ICAV), has seen tax-law firms, and offshore magic circle firms, set up Irish offices to handle Brexit-driven tax restructuring. These tools made Ireland the world's 3rd largest Shadow Banking OFC, and 5th largest Conduit OFC.
Ireland has been associated with the term "tax haven" since the U.S. IRS produced a list on the 12 January 1981. Ireland has been a consistent feature on almost every non-governmental tax haven list from Hines in February 1994, to Zucman in June 2018 (and each one in-between). However, Ireland has never been considered a tax haven by either the OECD or the EU Commission. These two contrasting facts are used by various sides, to allegedly prove or disprove that Ireland is a tax haven, and much of the detail in-between is discarded, some of which can explain the EU and OCED's position. Confusing scenarios have emerged, for example:
The next sections chronicle the detail regarding Ireland's label as a tax haven (most cited Sources and Evidence), and detail regarding the Irish State's official Rebuttals of the label (both technical and non-technical). The final section chronicles the academic research on the drivers of U.S., EU, and OCED, decision making regarding Ireland.
Ireland has been labelled a tax haven, or a corporate tax haven (or Conduit OFC), by:
Ireland has also been labelled related terms to being a tax haven:
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