Ireland has put an end to the “double Irish” tax loophole high-profile multinationals and tech companies have capitalized on in recent years.
During Tuesday’s Irish Budget 2015 announcements, Minister for Finance Michael Noonan confirmed that the “double Irish” tax deal will no longer be offered to corporations as of January 2015. All companies currently operating within the tax deal will have until December 31, 2020 to adjust their financial practices accordingly.
“I am abolishing the ability of companies to use the ‘double Irish’ by changing our residency rules to require all companies registered in Ireland to also be tax resident,” he said during the budget speech.
The “double Irish” has permitted corporations registered in Ireland to be tax resident in other countries – most often countries without corporate income taxes, such as Bermuda. Multinationals have significantly reduced their taxes, particularly on intellectual property, by directing revenue from operations based in Ireland to second Irish subsidiaries tax resident elsewhere (hence the “double Irish”).
For example, Forbes reports that Facebook has “flipped more than $700 million to the Cayman Islands in a Double Irish.” With Dublin-registered subsidiaries tax resident in Bermuda, Google and Microsoft brought their overseas tax rates down to the single digits.
Combined with Ireland’s highly educated and English speaking workforce, blossoming tech scene, business initiatives and already low corporate tax rate, the double Irish has been a contributing factor in Ireland’s strong appeal to corporations looking to establish or re-locate their European headquarters, including Google, Twitter, Facebook, Apple and eBay.
However, Ireland’s allowance of the double Irish has come under heavy fire in recent months, with European Union and US officials calling for an end to the loophole.
Minister Noonan alluded to this on Tuesday, saying “Aggressive tax planning by the multinational companies has been criticized by governments across the globe and has damaged the reputation of many countries.”
Following the announcement, some companies registered in Ireland pledged to work within the new regulations. “As we’ve always said, it’s for governments to decide the law and for companies to comply with it . . . We’re deeply committed to Ireland and will work to implement these changes as they become law,” Google said in a statement.
Having cracked down on the double Irish, Minister Noonan asserted that Ireland would not be changing its corporate tax rate, which, at a relatively low 12.5% (eighth lowest in the EU; the US’ is 35%) has also been subject to criticism and debate.
“The 12.5% tax rate remains at the heart of this,” Noonan said. “The government has successfully protected the 12.5% tax rate in recent years. The 12.5% tax rate never has been and never will be up for discussion. [It is] settled policy. It will not change.”