Category: Ireland

Ireland: FATCA Update

On Friday, 27 June 2014, the Irish Revenue Commissioners (in conjunction with the Department of Finance) finalised the relevant Regulations with respect to FATCA. These Regulations will come into operation on 1 July 2014. As readers will be aware, the Irish and US Governments signed an intergovernmental agreement (“Irish IGA”)… – Continue reading

Ireland in trouble with EU over possible Apple Inc. (AAPL) tax haven

In an era when many companies seek international solutions that in simpler times might have been openly labeled “tax evasion,” governments around the world are seeking to ensure they are not cheated of legally due taxes by what is now euphemistically called “profit shifting.” Apple Inc. (AAPL) has been keeping… – Continue reading

Tax all profit of firms incorporated here’

US multinationals incorporated in Ireland should have their entire global operations taxed here, a leading academic has claimed. Addressing the Oireachtas sub-committee on global taxation yesterday, Jim Stewart, associate professor in finance at Trinity College Dublin, said that existing tax residency rules, for multinational firms, are “extremely ambiguous” and suggested… – Continue reading

European Union is examining overseas tax breaks for Apple, Starbucks and Fiat

The European Commission raised pressure on Ireland, the Netherlands and Luxembourg over their corporate tax practices, saying it was investigating deals the countries have cut with Apple, Starbucks and Fiat. The Commission, the executive body of the European Union, is looking at whether the countries’ tax treatment of multinationals that… – Continue reading

EC launches Apple tax investigation

EC launches Apple tax investigation The European Commission has launched a formal investigation into Apple’s tax arrangements in Ireland The EC has announced three “in-depth investigations” into the transfer pricing arrangements on the corporate taxation of Apple, Starbucks in the Netherlands and Fiat in Luxembourg, as to whether they comply… – Continue reading

Apple’s principal Irish company became stateless for tax purposes from 2006

Apple Operations International, the principal Irish holding company for foreign subsidiaries, was not always stateless for tax purposes based on the last filed accounts in Ireland. It stopped paying tax in Ireland from 2006, based on US Senate Permanent Subcommittee on Investigations evidence. The most explosive revelation in the May… – Continue reading

Ireland Provides Guidance On Tax Transparency Work

Ireland’s revenue agency has launched a dedicated Automatic Exchange of Information (AEOI) webpage containing information and links to documents on a range of initiatives. In unveiling the page, Revenue said that Ireland fully supports the global move towards AEOI. The page provides guidance on the Intergovernmental Agreement reached with the… – Continue reading

Apple, Starbucks Tax Deals With Irish, Dutch Probed by EU

Tax breaks for Apple Inc. (AAPL:US), Starbucks Corp. (SBUX:US) and Fiat Finance & Trade SA in three European Union countries are under investigation by EU competition regulators in a clampdown on special treatment for companies. The EU is checking whether the tax deals in Ireland, the Netherlands and Luxembourg are illegal state aid, according to… – Continue reading

EU investigates tax rulings on Apple, Starbucks, Fiat

Reuters) – The European Commission raised pressure on Ireland, the Netherlands and Luxembourg over their corporate tax practices, saying it was investigating deals the countries have cut with Apple, Starbucks and Fiat. The EU is looking at whether the countries’ tax treatment of multinationals, which help to attract investment and… – Continue reading

European Commission to investigate Apple’s Ireland tax haven – report

Additional details on the allegedly impending investigation from the European Commission were not shared by the initial source, Ireland’s RTE, according to Reuters. A formal announcement of the investigation is expected to follow.It’s already been established through other investigations that Apple has not broken any laws in utilizing Ireland as a tax haven,… – Continue reading

EC to Investigate Apple’s (AAPL) Ireland Tax Haven: Report

Irish state broadcaster RTE reports that the European Commission had decided to launch a formal investigation into Apple (AAPL)’s tax arrangements in Ireland. An announcement is expected by EU’s Competition Commissioner to follow: “The European Commission is to open a formal investigation into Apple’s tax arrangements with Ireland. An announcement is expected to… – Continue reading

Europe opens tax probe into Apple in Ireland

The probe, announced on Wednesday by Europe’s competition commissioner Joaquín Almunia, will look into whether the low rate of tax Apple pays in Ireland breaks European state aid rules.   Apple pays less than two percent tax in the country — far less than the standard 12.5 percent corporation tax… – Continue reading

Ireland in U-turn on corporate tax avoidance; Accepts reality of reform

Having spent the past eighteen months claiming that Ireland does not facilitate international corporate tax avoidance despite overwhelming evidence to the contrary, the Irish Government has done a U-turn and has signalled that it is ready to prepare for the reality of reform. On Tuesday the Department of Finance published… – Continue reading

US Tax Cheats in Ireland Pocket Profits Worth Almost Half of GDP

It is a figure which Citizens for Tax Justice (CTJ), the US group which authored the report, says highlights Ireland’s popular use as a tax haven among US companies. Matt Gardner, executive director of the Institute on Taxation and Policy in Washington DC, tells IBTimes UK: “It’s a clear indicator… – Continue reading

Consultation puts tax law plans in spotlight

THE Department of Finance has launched a public consultation on how Ireland’s tax system might respond to proposed international changes. The Organisation for Economic Cooperation and Development (OECD) is already conducting a public discussion around its Base Erosion and Profit shifting (BEPs) project, which could see tax avoidance loopholes shut… – Continue reading

Stop bashing Ireland as a tax dodge: Ryanair CEO

Ireland has been “unfairly singled out” as a tax haven for corporations, Dublin-based Ryanair CEO Michael O’Leary said Monday on CNBC. “I wish we were, but we’re not,” he said. As one of Ireland’s wealthiest businessmen, O’Leary also described as “egregious” personal tax rates there. “The top tax rate … is about… – Continue reading

Federation to sign TIEA’s with Ireland and South Africa

BASSETERRE, St. Kitts, May 21st 2014 (CUOPM) – The St. Kitts and Nevis Federal Cabinet has paved the way for the signing of Tax Information Exchange Agreements (TIEAs) with Ireland and South Africa.   Cabinet has approved the draft agreements between officials of the respective countries. “Those negotiation exercises have since… – Continue reading

Corporate Tax: Apple, Google, Dr Dre & Ireland’s continuing stateless companies

Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading

Multinationals escape tax due to ‘exceptional’ rules, study claims

Large subsidiaries of multinationals, such as Apple and Google, which are based in Ireland are able to escape paying corporation tax due to an “exceptional” interpretation of tax laws by the Revenue Commissioners, a new study claims. A research paper by James Stewart, associate professor in finance at Trinity College… – Continue reading

Mauritian firm Ireland Blyth says Indian tax rules affecting investment

Mauritian conglomerate Ireland Blyth IBLP.MZ says uncertainty over new tax rules by key trading partner India has affected its business by putting off investors using the Mauritius financial center to invest in India. Nicolas Maigrot, chief executive of the group which has a wide range of interests in financial services,… – Continue reading

Irish Corporate Tax: Government begins publicity offensive on tax with irrelevant paper

Irish Corporate Tax 2014: The Government today issued what it calls a technical paper on effective corporation tax rates to effectively confuse the public by avoiding the key issues about its facilitation of corporate tax avoidance. It’s irrelevant to the core issues as it is simply trying to divert attention… – Continue reading

Ireland’s effective corporation tax at approximately 10.8pc over a decade – report

IRELAND’s effective rate of corporation tax averaged between 10.7pc and 10.9pc over the last decade, a report by the Department of Finance states. It claims that the tax paid by companies is close to the 12.5pc headline rate, amid controversy over the amount paid by multinationals here. The Department commissioned… – Continue reading

Irish Economy 2014: Ibec forecasts robust growth in tax-related services exports

Irish Economy 2014: Ibec, Ireland’s leading business lobby group, in its latest economic forecast today forecasts “continued robust growth in services exports and a recovery in goods exports.” The strong growth in services mainly reflects tax-avoidance related revenue diversions to Ireland that do not reflect local economic activity. If the… – Continue reading

Corporate Tax: OECD’s Saint-Amans says “Double Irish Dutch” sandwich tax scheme will be axed

Corporate Tax Reform: The Organisation for Economic Co-operation and Development (OECD) held a briefing and webcast at its Paris headquarters Wednesday on its Base Erosion and Profit Shifting (BEPS) project and Pascal Saint-Amans, the director of the OECD’s tax centre confirmed that “Double Irish Dutch” sandwich tax schemes, which involve… – Continue reading

Double taxation risk in chasing multinational companies

A call to tax technology companies such as Apple and Google in the countries where they have substantial activities has re-ignited concerns companies may be taxed twice and stop business altogether. The Organisation for Economic Co-operation and Development, which is working on a global plan to prevent companies from avoiding paying… – Continue reading

Internet groups face global tax crackdown

A looming global crackdown on aggressive tax avoidance is set to stop internet companies slashing bills by routing profits to havens. Plans to “restore taxation” in the countries where digital companies make their sales and base their headquarters were set out on Monday in the first international response to the… – Continue reading

Multinationals face new rules on aggressive tax avoidance

OECD plan to make practice of shifting locations ineffective New rules aimed at preventing the type of aggressive tax avoidance schemes run by some of the largest multinational employers here will begin to be introduced in September, according to a draft report seen by The Irish Times . Structures that artificially shift… – Continue reading

Luxembourg Ordered to Give EU Tax-Deal Detail Amid Aid Probe (1)

European Union competition watchdogs ordered Luxembourg to hand over details of tax breaks for businesses after they said the Grand Duchy was hindering a state-aid probe spanning several EU nations. Luxembourg refused to deliver details concerning the 100 largest companies benefiting from a special program for companies whose profits stem… – Continue reading

Companies’ Offshore Profits Keep Piling Up

U.S. corporations added at least $206 billion to their stockpiles of offshore profits last year, parking earnings in low-tax countries until Congress gives them a reason not to. They have accumulated $1.95 trillion outside the U.S., up 11.8 percent from a year earlier, according to securities filings from 307 corporations…. – Continue reading

British Virgin Islands: BVI & Canada: Down To business – TIEA Now Effective

The Canada-BVI Tax Information Exchange Agreement (“TIEA”) came into force on 11 March 2014. The TIEA was signed in May 2013, and the effective date provisions are set out in Article 13 of the Agreement. The BVI is now party to 25 TIEAs. What are the benefits? The BVI/Canada TIEA is significant due… – Continue reading

Ireland’s Noonan Clarifies Corporate Tax Developments

Changes to Ireland’s residency rules, designed to eliminate mismatches between tax treaty partners, have not yet affected the residency status of any company, Finance Minister Michael Noonan has confirmed. The reforms were introduced in Noonan’s 2014 Budget and included in this year’s Finance Bill. They are intended to prevent companies… – Continue reading

More multinationals head for tax haven

US companies appear to be thumbing their noses at a global crackdown on tax avoidance, with share registry group Computershare reporting an increase in multinationals re-incorporating in Ireland. In a briefing to investors on its regional outlook last week, Computershare said its Irish division had noticed ”further momentum in US… – Continue reading