Funds at large when ‘Double Irish’ ends

Question for MNCs is where now to house the loot

Facebook Ireland had a turnover of €1.78 billion in 2012 but paid €770 million in royalty payments to a fellow Irish subsidiary believed to be tax resident in the Caribbean. Photograph: Chris Ratcliffe/Bloomberg

The global changes to how multinationals are taxed is of huge importance to Ireland and, as research published by the Department of Finance this week notes, is both a risk and a challenge because of that. Multinationals form a significant part of our economy, are important suppliers of well-paid jobs and can be notoriously mobile.

The announcement this week that the “double Irish” is to close by 2020 for current users of the tax structure leaves enormous amounts of money looking for a home. The figures are huge in the context of Ireland’s gross national product and the Government’s tax take. As this newspaper reported earlier this year, Google’s main Irish subsidiary had a turnover of €17 billion in 2013. However, it also booked administrative expenses of €11.7 billion, much of which was royalty payments directed towards Bermuda by way of the double-Irish structure.

Facebook Ireland had a turnover of €1.78 billion in 2012 but paid €770 million in royalty payments to a fellow Irish subsidiary believed to be tax resident in the Caribbean. There are, no doubt, lots of other examples involving enormous sums. If, as the department and, indeed, Pascal Saint-Amans of the OECD appear to believe, tax havens’ days are up in relation to housing intellectual-property receipts, then the question for the multinationals is where to house the loot so they can avoid as much tax as possible.

Ireland has obvious reasons to believe it can make a reasonable pitch, and the consultation process the department initiated was an effort to get as much help as it could in that regard.

READ MORE

The list of those who got involved includes: Sinn Féin, KPMG, Tasc, Chambers Ireland, Finfacts, Social Justice Ireland, Matheson, Ibec, the Green Party, Sheila Killian, PwC tax director network, Amcham, Deloitte, the Irish Funds Industry Association and Washington DC-based Tax Executives Institute, Inc.