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Whereas Ireland's headline corporation tax rate is 12.5%, Ireland's BEPS tools enable an effective tax rate of 0% to 2.5% to be achieved, depending on which BEPS tool is used. [c] Ireland has been associated with U.S. multinational profit shifting to avoid taxes since the U.S. IRS produced a list on the 12 January 1981.
A source of controversy is the effective tax rate of Ireland corporation tax system, of which the independent evidence is that it is less than 4%, and as low as 0.005% for major U.S. multinationals (see Irish effective corporate tax rate). [35] Ireland's Corporate Tax System has seen Ireland labelled a tax haven, and in June 2018, academics ...
Two of the world's main § Leaders in tax haven research, estimated Ireland's effective corporate tax rate to be 4%: James R. Hines Jr. in his 1994 Hines–Rice paper on tax havens, estimated Ireland's effective corporate rate was 4% (Appendix 4); [29] Gabriel Zucman, 24 years later, in his June 2018 paper on corporate tax havens, also ...
The Irish State refutes tax haven labels as unfair criticism of its low, but legitimate, 12.5% Irish corporate tax rate, [132] [133] which it defends as being the effective tax rate (ETR). [134] Independent studies show that Ireland's aggregate effective corporate tax rate is between 2.2% to 4.5% (depending on assumptions made).
The Central Bank of Ireland has addressed this aspect of Section 110 SPVs by upgrading the little used L–QIAIF regime in February 2018 to give the same tax-free structure to hold Irish assets via debt instruments, but in a confidential structure (discussed further in Ireland as a tax haven).
Irish QIAIFs have been used to circumvent international regulations, [45] on avoiding tax laws in the EU and the U.S. [46] [47] Irish QIAIFs can be combined with Irish corporate BEPS tools (e.g. the Orphaned Super–QIF), [48] to create confidential routes out of the Irish corporate tax system to other tax havens such as Luxembourg, [5] the ...
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The liquidator realises the value of the company's assets and applies the proceeds in repayment of the company's creditors in order of their preference. Certain creditors have preferential status (e.g. secured creditors, tax creditors, & employees) and must be repaid in full to the extent that the company's assets permit them to be. The balance ...