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Capital allowances are a replacement of accounting depreciation, which is not generally an allowable deduction in UK and Irish tax returns. Capital allowances can therefore be considered a form of 'tax depreciation', a term more widely used in other tax jurisdictions such as the US. If capital expenditure does not qualify for a form of capital ...
In September 2009, the commission recommended that the Irish State provide capital allowances for the acquisition of intangible assets, creating the CAIA BEPS tool. [81] [82] The 2009 Finance Act, materially expanded the range of intangible assets attracting Irish capital allowances [79] deductible against Irish taxable profits.
Acceptance of Irish capital allowance charges in the GILTI calculation. Ireland's most powerful BEPS tool is the capital allowances for intangible assets scheme (i.e Apple's Green Jersey). With TCJA participation relief, U.S. multinationals can now achieve net effective U.S. tax rates of 0% to 2.5% via this Irish BEPS tool. In June 2018 ...
[24] [60] The passing of the 1997 Taxes and Consolidated Acts laid the legal foundations for the base erosion and profit shifting (BEPS) tools used by U.S. multinationals in Ireland (e.g. the Double Irish, the Capital Allowances for Intangible Assets and the Section 110 SPV), to achieve an effective Irish CT rate, or ETR, of 0–2.5%.
Ireland's corporate tax system has base erosion and profit shifting (BEPS) tools, such as the Double Irish (used by Google and Facebook), the Single Malt (used by Microsoft and Allergan), and the Capital Allowances for Intangible Assets (CAIA) (used by Accenture, and by Apple post Q1 2015); in June 2018, academics showed they are the largest ...
In 2015 there were a number of “balance-sheet relocations” with companies who had acquired IP while resident outside the country becoming Irish-resident. It is possible that companies holding IP for which capital allowances are currently being claimed could become non-resident and remove themselves from the charge to tax in Ireland.
Ireland's capital allowances for intangibles scheme was the BEPS structure to secure it as an ultra-low tax (i.e. 0-3% in perpuity) location for U.S. multinationals, that is in full compliance with all OECD guidelines, and the OECD BEPS project. [63] However, the U.S. and EU's new tax regimes deliberately "override" these IP-based BEPS tools.
The crisis caused the Irish State to look for new BEPS tools, and in September 2009, the Commission on Taxation, [24] [25] recommended extending Irish capital allowances to intangible assets and intellectual property in particular; the "capital allowances for intangible assets" or "Green Jersey" BEPS tool, was created in the 2009 Finance Act ...