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Seamus Coffey's 2016 Review of Ireland's Corporation Tax Code chronicled how the EU withdrew the exemption from State-aid rules for Ireland's special tax rate of 10% in 1996–1998, however, Ireland countered the EU withdrawal by lowering the entire Irish standard rate of corporate tax from 40% to 12.5% over 1996–2003 (see § Historical rates ...
A source of controversy is the effective tax rate of Ireland corporation tax system, of which the independent evidence is that it is less than 4%, and as low as 0.005% for major U.S. multinationals (see Irish effective corporate tax rate). [35] Ireland's Corporate Tax System has seen Ireland labelled a tax haven, and in June 2018, academics ...
The Irish State refutes tax haven labels as unfair criticism of its low, but legitimate, 12.5% Irish corporate tax rate, [201] [202] which it defends as being the effective tax rate ("ETR"). [203] Independent studies show that Ireland's aggregate effective corporate tax rate is between 2.2% to 4.5% (depending on assumptions made).
24.5%; 20% corporate tax plus a 4% Jehad tax plus a 0.5% tax on corporate income to pay for stamp duties [135] — — — Taxation in Libya Liechtenstein [136] [137] 12.5% 3% [138] 22.4% [139] 8.1% (standard rate) 3.8% (lodging services) 2.5% (reduced rate) [140] 0% for share sales, 24% for real estate Taxation in Liechtenstein Lithuania ...
The Irish State refutes tax haven labels as unfair criticism of its low, but legitimate, 12.5% Irish corporate tax rate, [132] [133] which it defends as being the effective tax rate (ETR). [134] Independent studies show that Ireland's aggregate effective corporate tax rate is between 2.2% to 4.5% (depending on assumptions made).
Seamus Coffey posted several articles in 2018 on the rise in Irish "intangible allowances", which hit €35.7 billion in 2016, or €4.5 billion of Irish corporate tax avoided at the 12.5% rate. [111] This is consistent with 2018 research showing that the "Green Jersey" is the largest BEPS tool in the world.
The quoted income tax rate is, except where noted, the top rate of tax: most jurisdictions have lower rate of taxes for low levels of income. Some countries also have lower rates of corporation tax for smaller companies. In 1980, the top rates of most European countries were above 60%. Today most European countries have rates below 50%. [1]
Apple would, therefore, owe back-taxes to each individual EU country, from which these royalties were paid (and not to Ireland). As all other EU countries have corporation tax rates materially in excess of Ireland's 12.5% corporation tax rate, the total Apple effective taxes owned, in this scenario, would be materially in excess of €13 billion.