Showing posts with label CCCTB. Show all posts
Showing posts with label CCCTB. Show all posts

Wednesday, May 27, 2015

27/5/15: CCTB is Baaaack...


It's Happy Hour again in Brussels, as the EU is reviving its plans for tax harmonisation across the continent.

At stake, the EU proposal for CCCTB, or Common Consolidated Corporate Tax Base, which would set the first precedent for tax harmonisation, outside Vat. As reported in the media, the plans appears to have support from the EU Commission (predictably), France (predictably) and Germany 9again, predictably). UK (predictably) is opposed: http://www.cityam.com/216514/uk-brushes-aside-german-tax-plan.

Today, the EU officials are discussing how to tackle tax avoidance and create a system of “fair, transparent and growth friendly” corporation taxation with discussion expected to “feed into” an announcement on corporation tax in June.

Key article on this is here: https://global.handelsblatt.com/edition/183/ressort/finance/article/a-tax-collision-course.

Friday, September 13, 2013

13/9/2013: Another month, another 'look into' Irish tax rules

The regular readers of this blog are aware that I try to track the more important news items concerning Ireland's corporate tax policies. The links to these stories can be successively follows from here: http://trueeconomics.blogspot.ie/2013/08/1982013-tax-haven-ireland-in-2009-news.html

Two more items from today are worth listing in addition to the above:

  1. An article from the Irish Independent (http://www.independent.ie/business/irish/state-to-lift-lid-on-us-firms-secret-tax-rulings-29575810.html). Couple of selective quotes: "Details of how multinational companies' tiny tax bills are calculated are to be revealed by the State for the first time." And per usual disclosure that the Stockholm Syndrome patients must have: "Irish authorities have always insisted that there are no special tax deals for companies. Under Irish law, all businesses are supposed to be subject to the same laws and tax rates." Alas, as article notes: "This is the first time information about how Ireland taxes big corporations has ever been shared outside of the Revenue Commissioners and the companies themselves... Tax rulings are so confidential that even the Department of Finance is never given details by Revenue of individual cases." Ok, nothing to see there, folks, it's just so we like secrets, we've just decided to have our own Area 51... cause we like it that way, not cause there's any smoking guns or something...
  2. And so we don't really have to worry about out tax policies, as the Government says we shouldn't, here's a article from the Irish Times (http://www.irishtimes.com/business/economy/eu-finance-ministers-put-state-s-tax-regime-in-spotlight-1.1525893). More selective quotes: "Ireland is likely to face tough questions about its corporate tax regime when EU finance ministers gather today in Vilnius for a two-day meeting, following confirmation that the European Commission has begun a preliminary inquiry into the country’s tax practices." Repeat with me... there is nothing in these codes to worry about. "... Ireland, Luxembourg and the Netherlands will be under pressure to defend their tax structures amid claims that all three countries may have offered tax deals to specific companies in breach of state aid rules." Clearly all G7 nations, plus all EU nations are just being taken for a ride by someone, somewhere, who got it into their heads that there is something questionable going on with Irish tax system. In case you have doubts: "Dublin moved quickly yesterday to deny suggestions that Ireland had engaged in anti-competitive behaviour, with Taoiseach Enda Kenny insisting that the State was committed to a “transparent” system. Tánaiste Eamon Gilmore said that Ireland’s tax regime was open and “statute-based”. He said his understanding was that the inquiry was part of an “information-gathering exercise which is done from time to time”." Yes, that's right folks: 'from time to time' 'routine stuff'... Would Mr Gilmore - with his wisdom and perfect knowledge of the matters suggest to us when was the last time the 'routine' thingy 'gathering' such information was done? Or when was the last time G7 and G20 discussed Ireland's tax rule before 2011-2013? Just for the record, please, Mr Gilmore?

Monday, August 19, 2013

19/8/2013: 'Tax Haven' Ireland in the (2009) news again

I've been tracking articles relevant to the debate on the tax haven status of Ireland in relation to corporation tax for some time now.

Here's the last link which sets the chain of previous links on the topic:
http://trueeconomics.blogspot.it/2013/06/1062013-corporate-tax-haven-ireland.html

And since the above, I had couple of posts relevant to the subject:
http://trueeconomics.blogspot.it/2013/06/1662013-minister-in-northern-ireland-is.html
and
http://trueeconomics.blogspot.it/2013/07/2272013-g20-spells-out-squeeze-on-tax.html

Here are couple of most recent ones:

The Guardian covers 2009 case of Vodafone in two stories:
http://www.theguardian.com/business/2013/aug/18/vodafone-tax-deal-irish-office
http://www.theguardian.com/business/2013/aug/18/tax-vodafone-dublin
while the Tax Justice Network responds to the OECD Action Plan on corporate tax avoidance, explicitly identifying Ireland as a 'tax haven'
http://blogs.euobserver.com/shaxson/2013/07/19/press-release-response-to-oecd-action-plan-on-corporate-tax-avoidance/
and lastly the editorial in the EUObserver that also labels Ireland a 'tax haven':
http://blogs.euobserver.com/shaxson/2013/05/02/the-capture-of-tax-haven-ireland-the-bankers-hedge-funds-got-virtually-everything-they-wanted/

Note 1: The Guardian article references EUR67 million rebate on EUR1.04 billion in Vodafone dividends booked into Luxembourg. The dividends were paid on underlying revenues that were booked into Irish GDP and, thus, into our GNI (netting out transfers of royalties etc).These, in turn, required a payment of 0.59% of GNI-impacting activities to the EU Budget. While is is hard to exactly assess how much Irish Exchequer unnecessarily paid into the EU budget due to Vodafone activities, the amount is probably in excess of EUR 5 million and this compounds the transfers of EUR67 million referenced by the Guardian.


Note 2: I am not as much interested in the legal definitions of a tax haven (there are none and, thus, technically-speaking no country can be definitively labeled a tax haven) or in specific groups' definitions of the tax haven (the OECD definition is so convoluted, it virtually makes it impossible for any country with any global political clout - including that acquired via membership in the EU - to be labeled one, while the Tax Justice Network definition is broad enough to potentially include a large number of countries). I am concerned with the spirit of the concept - rent-seeking via tax arbitrage, and with the potential fallout from this in terms of distortions to economic development models and risks arising from same.

Note 3: A 'thank you' is due to a number of people who reminded me - in the context of the Guardian articles linked above - that Ireland charges a 25% corporate income tax on non-trading income. TY to    

Monday, July 22, 2013

22/7/2013: G20 Spells Out a Squeeze on Tax Arbitrage

Last week we saw the conclusion of the G20 Finance Ministers and Central Bank Governors meeting in Moscow. The meeting covered, in part, financial regulation and international taxation issues, aimed at addressing, as the IMF put it, "international spillovers of national tax policies".

Here's what the basic set of the proposals discussed implies for Ireland - a country at the centre of these spillovers in the euro area and largest per-capita beneficiary of the international tax arbitrage after Luxembourg.

The OECD-prepared, G20 discussed 'Action Plan' on Base Erosion and Profit Shifting (BEPS) covers loads of technical ground. The main points of relevance to Ireland's real economy are:

  1. Tax issues relating to the Digital Economy - including coverage of tax application to services, geographic distribution of tax revenues etc. In the nutshell, the G20 will aim to adapt international direct and indirect taxation rules to the digital economy, including attribution of profit 'together with the character and source of income'. In simple terms, aggressive tax base shifting from, say the UK-sold advertising revenues to, say Ireland-based pro forma sales centre. In other words, the rules will challenge the system on which much of the Ireland's comparative advantage in ICT and financial services currently rests. The threat is more genuine in my view in the case of ICT services than in the case of financial services.
  2. Tighter controls over Controlled Foreign Company rules - a relatively minor issue from the point of view of Irish real economy, but having a potential to impose small adjustment on our official GDP.
  3. Reduce artificial avoidance of tax application, presumably including by schemes such as Double Irish. This has potentially strong adverse impact on Irish economy.
  4. Intangibles transfers within the company group are to be tightened, to reduce effectiveness of transfer pricing. Once again, this suggests pressures on IP tax arbitrage and licenses arbitrage - a core competitive point for Ireland.
  5. The Plan also aims to (explicitly) develop rules to align profits with value creation. Bad news for major MNCs operations here.
  6. Beefing up of data, tax and transfer pricing documentation, and reporting compliance in line with BEPS proposals - an additional significant cost for Irish companies and MNCs, although this is symmetric for all other jurisdictions, so not an issue from comparative advantage of Ireland point of view.

In effect, many proposals link directly into CCCTB structure (see my analysis of this in the G8 context here):

  • Reporting on tax matters re-aligned to cover business activities and capital bases
  • Focusing on documentation of the location where key business risks and business processes are located
  • A country-specific breakdown of group profits and revenues
  • Common anti-avoidance regime
  • Services delivered on-line will migrate toward effective tax rates based on location of end-user of services
  • As KPMG analysis statesd: "Change in effective rate of tax on group profits where change in transfer pricing basis for profit attribution alters the mix of profits attributable to group members". Or in other words: kiss goodbye the key pillar of tax arbitrage in Ireland via consolidation of the tax base.
  • Tax base will migrate to the locations "of key functions and management and oversight of key risks"

So good luck eating that 'breakfast of champions' of the claims that the G20 proposals present no threat to Ireland's economic model. They might not spell a full-scale closure of the tax 'haven' we run, but they do present a significant costs and risks threat to our model, where it is reliant heavily on tax arbitrage. Not a catastrophe, but...

Tuesday, July 2, 2013

2/7/2013: Sunday Times June 23, 2013: G8 and Ireland


This is an unedited version of my Sunday Times article from June 23, 2013


As G8 summits go, the latest one turned out to be as predictable as its predecessors – an event full of reaffirmations of well-known conflicts and pre-announced news. In terms of the former, the Lough Erne meeting delivered some fireworks on Syria. On the latter, there was a re-announcement of the previously widely publicized Free Trade pact between the US and Europe. Another pre-announced item involved the EU, UK and US push for corporate tax reforms.

The two economic themes of the Logh Erne Summit agenda are tied at the hip in the case of our small open economy heavily reliant on FDI attracted here by the opportunities for tax arbitrage. As such, the G8 meeting agreement poses a significant threat for Ireland's model of economic development. Although it will take five to ten years for the shock waves to be felt in Dublin, make no mistake, the winds of uncomfortable change are rising.


The trade agreement, first announced by the Taoiseach months before the G8 summit, promises to deliver some EUR120 billion in net benefits for the EU economy. Roughly 90% of these are expected to go to the Big 5 economies of the EU, leaving little for the smaller economies to compete over. Behind these net gains there are also some regional re-allocations of trade that will take place within the EU itself.

In the short term, Ireland is well-positioned to see an increase in exports by the US multinationals operating from here and to some domestic exporters. The uplift in trade flows between Europe and the US may even help attracting new, smaller and more opportunistic US firms' investments. While tens of billions in trade for Ireland, bandied around by various Irish ministers, are unlikely to materialize, a small boost will probably take place.

However, over time, the impact of the EU-US trade and investment liberalisation can lead to sizeable reductions in MNCs activity here. Under the free trade arrangements, longer-term investment and production decisions will be based on such factors as cost considerations, as well as concerns relating to access to the global markets, and taxes.


Consider these three drivers for future trade and economic activity in Ireland in the context of the G8 summit and other recent news.

On the cost competitiveness side, we have had some gains in terms of official metrics of labour productivity and unit labour costs. Major share of these gains came from destruction of less productive jobs in construction and domestic services. Increase in revenues transferred via Ireland by some services exporters since 2004-2007 period further contributed to improved competitiveness figures.

Once when we control for these temporary or tax-linked 'gains' Ireland is still a high cost destination for investors compared to the majority of our peers.  As reflected in Purchasing Managers Indices, since the beginning of the crisis, Irish producers of goods and services have faced rampant cost inflation when it comes to prices of inputs. Earnings and wages data for 2009-2012, released this week, show labour costs rising across the exports-oriented sectors. Lack of new capital, R&D and technological investments further underlines the fact that much of our productivity gains are related to jobs destruction and transfer pricing by the MNCs.

When the tariffs and other barriers to EU-US trade come down, some multinationals trading into Europe will have fewer incentives to locate their production in Ireland. This effect is likely to be felt stronger for those MNCs which trade increasingly outside the EU, focusing more on growth opportunities around the world. Based on experiences with other free trade areas, such as NAFTA and the EU, this can lead to increased on-shoring of FDI back into the US and into core European states, away from smaller economies that pre-trade liberalization acted as entrepots to Europe.


The tax dimension of the G8 agreement will be the most significant driver for change in years to come.

The G8 clearly outlined the reasons for urgency in dealing with the issues of both tax evasion (something that does not apply in Ireland's case) and tax avoidance (something that does have a direct impact on us). These are structural and will not dissipate even when the G8 economies recover.

All of the G8 economies are struggling with heavy public and private debt loads and/or high domestic taxation levels. All are stuck in a demographic, social security and pensions costs whirlpools pulling them into structural insolvency. In other words, not a single G8 nation can afford to lose corporate revenues to various tax havens.

In line with the longer-term nature of the drivers for tax reforms, G8-proposed agenda can also be seen in the context of quick, easier to implement changes and longer-term structural realignment of tax systems.

The first wave of tax reforms outlined in principle by the G8 Summit will focus on tightening some of the more egregious loopholes, usually involving officially recognised tax havens. On the European side, this will spell trouble for the likes of Gurnsey and Jersey. The first round will also target easy-to-spot idiosyncratic tax arrangements, such as the Double Irish scheme and similar structures in Holland. Shutting down Double Irish will impact around a quarter of our trade in services, or roughly EUR13-15 billion worth of exports – much more than the EU-US Free Trade Agreement promises to unlock. The cut can be quick, as much of this trade involves electronic transactions - easy to shift and costless to re-domicile.

Over time, as changes in tax systems bite deeper into the structure of European tax regimes, losses of exports and FDI are likely to mount. To raise substantive new tax revenues, the EU members of G8 will have to severely cut back tax advantages accorded to countries like Ireland by their competitive tax rates.

Free Trade zones are notorious for amplifying the role of comparative advantage in determining where companies choose to domicile. Thus, to achieve a level the playing field for trade-related investments within the EU, either the effective tax rates will have to be brought much closer to parity across the block, or the basis for taxation must be redistributed more evenly across producers and consumers of goods and services.

Forcing all EU countries to harmonise the rates of tax would be politically difficult. Instead, there is a ready-to-use solution to the problem of redistributing tax revenues available since 2009 - the Common Consolidated Corporate Tax Base (CCCTB).

Under this mechanism companies selling goods and services from Ireland into European markets will report separate profits by each country of sales. These profits will then be reassigned back to the countries where each company has operations on the basis of a complex formula taking into the account company sales, employment levels and capital structure on the ground. The re-allocated profits will then be subject to a national tax rate. The end game from the CCCTB for Ireland will be effective end to the transfer pricing that goes along with the current system.

The EU Commission analysis claimed that with full cooperation, the enhanced CCCTB implementation will lead to an 8% rise in tax revenues across the EU. The main beneficiaries of these gains will be the Big 5 member states. The total net impact of CCCTB on all EU member states is expected to be nearly zero.

This suggests some sizeable reallocations of economic activity and tax revenues away from the smaller member states, like Ireland, in favour of the larger member states. January 2011, study by Ernst & Young for the Department of Finance concluded that Ireland can sustain one of the largest drops in tax revenues in the euro area due to CCCTB implementation. The estimates range up to 5.7% Government revenue decline, with our effective corporate tax rate rising to 23%, GDP falling by 1.6%-1.8%, and employment declining by 1.5%-1.6%.

The Ernst & Young report was compiled based using data for 2005. Since then, Irish economy's reliance on services exports grew from EUR 49.5 billion or under 31% of GDP to EUR90.7 billion or close to 56% of GDP. With services exports being a prime example of a tax-sensitive sector in the economy, we can safely assume that the above estimates of the adverse impact of CCCTB on Irish economy are conservative.

The CCCTB matches nearly perfectly the G8 Action plans relating to the issues of tax avoidance. It also fits the objectives of the OECD plan on addressing taxation base erosion and profit shifting which the OECD is preparing for the Finance Ministers and Central Bank Governors of the G20 in July.

While much of the impact of this week's G8 summit remains the matter for the future, there is no doubt that the G8 push toward curtailing aggressively competitive tax regimes is real.  In my view, Ireland has, approximately between five and ten years before our competitive advantage is severely eroded by the EU and the US efforts to coordinate the effective rates of taxation and consolidate reporting and payment bases for corporate profits. We must use these years wisely to build up our technological capabilities and develop a skills-based high-value added and highly competitive economy.



Box-out:

The latest data on the duration of working life (a measure of the number of years a person aged 15 is expected to be active in the labour market over their lifetime) shows that in 2000-2002, on average, European workers spent 32.9 years in employment or searching for jobs. This number rose to 34.7 years by 2011. In Ireland, the same increase in duration of working life took Irish workers from spending on average 33.3 years in labour market activities in 2000-2002 to 34.0 years in 2011. The increase in years worked in the case of Ireland was the third lowest in the euro area. In 2011, duration of working life ranged between 39.1 and 44.4 years in the Nordic countries and Switzerland – countries with much more sustainable pensions costs paths than Ireland. The significance of this is that given our pensions, housing and investment crises, Irish workers can look forward to spending some four-to-five years more working to fund their future retirement. Aside from a dramatic greying of our working population this means that even after the economic recovery takes hold, there might be no jobs for today's younger unemployed, as the older generations hold onto their careers for longer.

Sunday, May 26, 2013

26/5/2013: Corporate Tax Haven Ireland Weekly Links Page

"Taxes are not up to Google," Schmidt reiterated. "If the international tax regime changes we will follow. But virtually all American companies have structures like this; this is how the international tax regime works. The fact of the matter is if we pay more tax in one area, we pay less somewhere else."

Thus spoke Eric Schmidt of Google (http://www.wired.co.uk/news/archive/2013-05/22/eric-schmidt-tax) and guess what: he is right. Google is not breaking the law. It is the law that allows for countries, like Ireland, to follow beggar thy neighbour economic policies and strategies.

The issue is not the low tax rate, but the fact that various loopholes allow companies operating - allegedly in Ireland - to channel revenues from other countries into Ireland. This is not about exports from Ireland, and it is not about low tax regime in Ireland. When an MNC books revenue earned somewhere else to Dublin, MNC is not break a law. Instead, Ireland is facilitating transfer of funds that relate to value added activity elsewhere to its own economy. This, in the nutshell, summarises the entire nature of Irish economic development strategy: take value added from somewhere else and appropriate it as Irish.


And in the spirit of usual weekly posts (see thread start on Irish Corporate Tax Haven here: http://trueeconomics.blogspot.ie/2013/05/1452013-corporate-tax-haven-ireland.html ): in this week, it is virtually impossible to list all Tax Haven Ireland links from around the world in a post, but here are some:

I shall stop there, for now...


Tuesday, May 14, 2013

14/5/2013: Corporate Tax Haven Ireland Weekly Links Page

Corporate Tax Haven Ireland in the news... again:
http://www.bloomberg.com/news/2013-05-13/europe-eases-corporate-tax-dodge-as-worker-burdens-rise.html

Update: Twitter in the news: http://www.telegraph.co.uk/technology/twitter/10056570/Twitter-CEO-resigns-as-UK-boss-after-accounting-fiasco.html
Note Irish connection.

Keep track of 'Tax Haven' view of Irish economic policies by following the links, starting here:
http://trueeconomics.blogspot.ie/2013/05/352013-not-week-goes-by-without-tax.html

Update 17/5/2013:
Three more stories, both relating to Google operations in Ireland:
http://www.independent.co.uk/news/business/comment/ben-chu-lets-not-get-bamboozled-by-google-in-the-global-tax-avoidance-debate-8620046.html
and
http://www.guardian.co.uk/technology/2013/may/16/google-told-by-mp-you-do-do-evil
and
http://www.independent.ie/business/irish/no-apology-for-low-tax-regime-as-google-debate-drags-on-richard-burton-29274843.html

I find it bizarre that Minister Bruton feels anyone on earth is asking for Ireland's apology. I think the point of this debate about the role of tax havens, like Ireland, is that policymakers around the world are seeking to close the loopholes through which companies engage in aggressive tax optimisation. Minister Bruton should focus on how Ireland can deal with this threat, as well as on how Ireland can develop a business platform (low tax is an important part of this platform) that actually operates on adding value here and not on beggaring our trading partners.

Minister Bruton's point about the need to create jobs in Ireland is nonsensical in the above debate. If we create jobs here on foot of value added in the Irish economy, then there is no problem with our MNCs activities globally, because low tax regime applies only to value added created here. Our trading partners have a problem with Ireland acting as a conduit for tax minimization whereby there is zero value added created in Ireland, but instead value added created elsewhere is booked via Ireland into tax havens. These forms of tax arbitrage do not create any jobs here in Ireland and generate no tax revenue here.

Friday, May 3, 2013

3/5/2013: Not a week goes by without a Tax Haven Ireland story?


More from the 'Tax Haven Island' newsflow, with a second story this week: "US firms paid an average tax rate of 8% profits in Ireland"
http://www.rte.ie/news/business/2013/0503/390280-us-corporations-tax/

I wonder if Michelle Obama's rumoured trip to Ireland will include a visit to such sunny tax haven locations as Barrow St, Dublin 2, or IFSC...


To track my posts on Irish Corporate Tax Haven, follow this link : http://trueeconomics.blogspot.ie/2013/05/252013-news-from-irish-tax-haven.html

Hat tip to:

Updated 08/05/2013: Two new links on the same subject:
and
Hat tip to: 

Thursday, May 2, 2013

2/5/2013: News from the Irish Tax Haven Central... Barrow St, D2

Given our Manufacturing PMI released today, things have to be looking sour when it comes to Irish GDP and GNP for Q1-Q2 2013. But, as always, never mind. In reality, Irish manufacturing is no longer the core driver of the economy. Instead, making stuff in Ireland (even if it was done for tax purposes with la-la-land accounting for value added) is now surpassed by billing revenues into Ireland by the services exporters, like Google.

Of course, the latter activity is also driven by tax arbitrage. And it is booming. So much so, that we now have a weekly international media instalment labeling Ireland a tax haven for services exporting MNCs.

Here's the latest one http://mobilebeta.reuters.com/special-report-how-google-uk-clouds-its-tax

And should you want to trace more stories on the same subject of Ireland as tax haven, here is the link to start with (keep tracing posted links): http://trueeconomics.blogspot.ie/2013/04/2742013-news-from-irish-corporate-tax.html

Saturday, April 27, 2013

27/4/2013: News from Irish Corporate Tax Haven Front


Latest instalment on Irish corporate tax haven: http://www.irishtimes.com/news/politics/oireachtas/irish-corporate-tax-rate-on-agenda-in-berlin-1.1374576

For those who want to read more, here are earlier links on same topic:
http://trueeconomics.blogspot.ie/2013/03/1832013-irish-corporate-tax-haven-in.html
Follow link at the end to more posts.

Monday, March 18, 2013

18/3/2013: Irish Corporate Tax Haven in the News, Again...


As you know, I have been gradually building up a record of articles in international and Irish media detailing the tax haven nature of our (Irish) tax laws and practices when it comes to corporation tax.

Here is the link to a new article by the WSJ on the topic:
http://online.wsj.com/article/SB10001424127887324034804578348131432634740.html

And here is a link to the most recent compilation of information & articles on the topic from my blog:
http://trueeconomics.blogspot.ie/2013/02/1822013-oecd-on-corpo-tax-havens-for-g20.html


Monday, February 18, 2013

18/2/2013: OECD on Corpo Tax Havens for G20


Just as G20 was starting to make noises about corporate tax havens at their meeting in Moscow (here) the OECD produced a convenient paper on the topic of tax avoidance. The paper is rather 'neutered' when it comes to language, but nonetheless offers couple fascinating insights, especially when it comes to Ireland. The report is titled "Addressing Base Erosion and Profit Shifting"


Per OECD: looking "specifically at the effects of income-shifting practices of United States based MNEs [Clausing, 2011],  …finds large discrepancies between the physical operations of affiliates abroad and the locations in which they report their profits for tax purposes: the top ten locations for affiliate employment (in order: the United Kingdom, Canada, Mexico, China, Germany, France, Brazil, India, Japan, Australia) barely match with the top ten locations for gross profits reporting (in order: the Netherlands, Luxembourg, Ireland, Canada, Bermuda, Switzerland, Singapore, Germany, Norway and Australia)."

And then:

"A report of the United States Congressional Research Service (Gravelle, 2010) concludes that there is ample and clear evidence that profits appear in countries inconsistent with an economic motivation. The report analysed the profits of United States controlled foreign corporations as a percentage of the GDP of the countries in which they are located. It finds that for the G-7 countries the ratio ranges from 0.2% to 2.6% (in the case of Canada). The ratio is equal to 4.6% for the Netherlands, 7.6% for Ireland, 9.8% for Cyprus, 18.2% for Luxembourg. Finally, the study notes that the ratio increases dramatically for no-tax jurisdictions with for example, 35.3% for Jersey, 43.3% for Bahamas, 61.1% for Liberia, 354.6% for British Virgin Islands, 546.7% for the Cayman Islands and 645.7% for Bermuda."

Now, of course, Ireland is a conduit via which profits of MNCs are off shored to zero tax jurisdictions, so one wonders, how much of Cayman's and BVI or Bahamas' 'profits' are really coming via Ireland.

The whole report addresses the issue of 'base erosion' in tax systems - the topic also close to heart to Ireland, as CCCTB proposals at the EU level are attempting to deal exactly with that problem and represent a massive threat to Ireland's tax optimisation industry.

Based on the data in the report, here are some revealing charts:



It is first worth noting that in absolute terms, corporate tax revenues overall are not that spectacular in the case of Ireland, contributing at an OECD average levels to the Exchequer. And these revenues have been falling, not rising, in importance despite a severe decline in GDP during the crisis:


Three interesting aspects per above are:

  1. It is pretty clear that Irish Exchequer has opted to transfer lower corporate tax burden onto the shoulders of individual Irish taxpayers, and that this process has started well before the onset of the crisis, but became dramatically pronounced in 2007-2009.
  2. It is also pretty clear that overall corporation tax is not an important source of Exchequer funding in recent years despite the Government numerous claims that the Corporation Tax receipts are robust and vital to the Exchequer.
  3. Domestic boom period was associated with a massive (relative) uplift in tax revenues from the corporation tax, while the MNCs/exports boom during the crisis did nothing of the sorts, showing clearly that the effect of MNCs activities on Irish economy (as instrumented by the Exchequer) is weak.
However, the trend toward deterioration in revenues importance to the Exchequer during the crisis (driving down the 2000-2011 average) stands in contrast with rising importance of the corporation tax in the decade of the 1990s:


It is illustrative to highlight the change in relative importance of the corporation tax revenues over the last decade:
Ireland stands out as the the country with the third largest decline in corporation tax importance in 2011 compared to 2000-2005 average. In contrast, in Switzerland, the corporation tax contribution in 2011 stood at a premium on 2000-2005 average.

Here are some links on the topic of the Irish corporate tax haven from the blog:

Enjoy.

Tuesday, January 22, 2013

22/1/2013: Merkel cites Ireland as one of 3 tax havens in Europe



A very interesting exchange between Angela Merkel and Francois Hollande talking at a public venue, as reported by the EUObserver : http://euobserver.com/political/118795

In particular, consider the following quote:

"When asked if it is "utopian" to think that one day there would be a federal EU state, Hollande said that the EU as it is today seemed "utopian" 50 years ago. "I accepted that we need to converge towards common budgetary policies. We need to have a similar discussions about taxes, for instance a common CO2 tax. It's true there are political risks, but we need to embrace our common destiny," he said.

"Merkel named Ireland, Malta and Cyprus as low-corporate tax havens: "I don't want to make a statement now that my fellow EU leaders will be upset about, but step by step we'll need to establish margins and then each country will have to choose how it fits in those margins. Your utopia is totally right.""

No comment needed.


Update: 9/2/2013: Here's another link on Apple use of Irish legal structures to reduce tax exposures in the US. And another one.

Update 10/2/2013: UK MNC Associated British Foods is implicated in tax minimisation scheme involving Ireland: http://www.guardian.co.uk/world/2013/feb/09/zambia-sugar-empire-tax

Tuesday, June 5, 2012

5/6/2012: Some recent links

Few past links worth highlighting:

An excellent article from PressEurop titled "The people have become a nuisance" focusing on real democratic deficit at the heart of modern Europe as exposed by the financial crisis.

An article on MEPs approving CCCTB.

And an article on symmetric pressure on Irish corporate tax rates from the other side of the pond.

A good summary (non-technical) of Basel III expected impact on European banks.

S&P Note on USD43-46 trillion refinancing cliff.

EU Commission assessment of the graveyard: Zombies Must Do as Zombies Have Done on fiscal deficits.

PMIs for June:
And add Spain at 41.8 for Services - the latest disaster. Along with Spanish unemployment chart worth taking a look at.

Soros on grave state of financial economics.

Excellent piece on the end of easy growth path for China.