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Former Finance Minister, Charlie McCreevy, reduced Irish corporate tax from 32% to 12.5% in the 1999 Finance Act, and whose 1997 Tax and Consolidation Act laid the framework for Ireland's BEPS tax tools. [1] Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax ...
As of November 2018, Ireland's corporate tax system is a "worldwide tax" system, with no thin capitalisation rules, and a holding company regime for tax inversions to Ireland. [93] Ireland has the most U.S. corporate tax inversions, and Medtronic (2015) was the largest U.S. tax inversion in history. [99]
In contrast, multinationals from countries with "territorial" tax systems, by far the most common corporate tax system in the world, do not need to use corporate–tax havens such as Ireland, as their foreign income is taxed at much lower rates. [192] For example, in 2016–17, US–controlled multinationals in Ireland:
Ireland ran a lower-than-expected 2021 budget deficit of around 4% of the economy due to a surge in tax receipts, including another record contribution from the corporate sector, the finance ...
The United States switched to a "territorial" tax system in the December 2017 Tax Cuts and Jobs Act (TCJA), causing American tax academics to forecast the demise of Irish BEPS tools and Ireland as an American corporate tax haven. However, by mid-2018, other tax academics, including the IMF, noted that technical flaws in the TCJA had increased ...
Single malt is another BEPS tax scheme designed to replicate the double Irish, which is impossible after 2020. [36] [37] It relies on specific wording in bi-lateral Irish tax treaties (particularly with Malta and the United Arab Emirates) to re-create the double Irish system and its effective tax rate of <1%.
The corporate tax havens opted out of the key articles (i.e. Article 12), [18] while emphasising their endorsement of others (especially Article 5 which benefits corporate havens using the § Employment tax BEPS system). Modern corporate tax havens like Ireland and Singapore used the OECD to diminish other corporate tax havens like Luxembourg ...
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 ...