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As of November 2018, Ireland's corporate tax system is a "worldwide tax" system, with no thin capitalisation rules, and a holding company regime for tax inversions to Ireland. [93] Ireland has the most U.S. corporate tax inversions, and Medtronic (2015) was the largest U.S. tax inversion in history. [99]
Ireland's corporation tax regime is integrated with Ireland's IFSC tax schemes (e.g. Section 110 SPVs and QIAIFs), which give confidential routes out of the Irish corporate tax system to Sink OFC's in Luxembourg. [8] This functionality has made Ireland one of the largest global Conduit OFCs, and the third largest global Shadow Banking OFC. [7]
One of the most contested aspects of Ireland's economy is the aggregate "effective tax rate" (ETR) of Ireland's corporate tax regime. 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 ]
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.
FY2021-22 was an uneventful year for the New Tax Regime as no new changes were announced except the relaxation of Income Tax filing for senior citizens over 75 years. [26] The government's tax policy for the near future was clearly outlined which indicated that all tax breaks will be gradually eliminated while maintaining a low tax rate.
Since the EU order in 2016, Ireland has made a number of changes to its corporate tax code and did the once unthinkable by dropping opposition to giving up its prized 12.5% corporate tax rate as ...
Pierre Moscovici, EU Tax Commissioner said on the 24 January 2017, the EU did not consider Ireland a tax haven, [5] but on 18 January 2018 said that Ireland was a tax blackhole. [27] Ireland has been associated with the term "tax haven" since the U.S. IRS produced a list on the 12 January 1981.
An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under Section 110 of the Irish Taxes Consolidation Act 1997 (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties.