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Capital allowance. Capital allowances is the practice of allowing tax payers to get tax relief on capital expenditure by allowing it to be deducted against their annual taxable income. Generally, expenditure qualifying for capital allowances will be incurred on specified capital assets, with the deduction available normally spread over many years.
Taxation in Ireland in 2017 came from Personal Income taxes (40% of Exchequer Tax Revenues, or ETR), and Consumption taxes, being VAT (27% of ETR) and Excise and Customs duties (12% of ETR). Corporation taxes (16% of ETR) represents most of the balance (to 95% of ETR), but Ireland's Corporate Tax System (CT) is a central part of Ireland's ...
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. [a] (The US was one of a small number of countries that did not use a "territorial" tax system, and taxed corporations on all ...
Acceptance of Irish capital allowance charges in the GILTI calculation. Ireland's most powerful BEPS tool is the capital allowances for intangible assets scheme (i.e Apple's Green Jersey). With TCJA participation relief, U.S. multinationals can now achieve net effective U.S. tax rates of 0% to 2.5% via this Irish BEPS tool. In June 2018 ...
Ireland's "headline" corporation tax rate is 12.5%, however, foreign multinationals pay an aggregate § Effective tax rate (ETR) of 2.2–4.5% on global profits "shifted" to Ireland, via Ireland's global network of bilateral tax treaties. These lower effective tax rates are achieved by a complex set of Irish base erosion and profit shifting ...
In January 2018, economist Seamus Coffey, Chairman of the State's Irish Fiscal Advisory Council, [67] and author of the State's 2017 Review of Ireland's Corporation Tax Code, [68] [69] showed Apple restructured ASI into another Irish IP–based BEPS tool, the Capital Allowances for Intangible Assets ("CAIA"), in Q1 2015. [14] [19] [17]
The International Financial Services Centre (IFSC) is an area of central Dublin and part of the CBD established in the 1980s as an urban regeneration area and special economic zone (SEZ) on the derelict state-owned former port authority lands of the reclaimed North Wall and George's Dock areas of the Dublin Docklands.
KPMG, "Intellectual Property Tax", 4 December 2017 Of the wider tax environment, O'Rourke thinks the OECD base-erosion and profit-shifting (BEPS) process is "very good" for Ireland. "If BEPS sees itself to a conclusion, it will be good for Ireland." Feargal O'Rourke CEO PwC (Ireland) "Architect" of the double Irish The Irish Times, 2015 The OECD G20 Base Erosion and Profit Shifting Project (or ...