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Ireland's taxation system is distinctive for its low headline rate of corporation tax at 12.5% (for trading income), which is half the OECD average of 24.9%. [ 32 ] While Ireland's corporate tax is only 16% of Total Net Revenues (see above), Ireland's corporate tax system is a central part of Ireland's economic model.
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. [a] (The US was one of a small number of countries that did not use a "territorial" tax system, and taxed corporations on all ...
The Irish tax code considers IRL2 a Bermuda company (used the "managed and controlled" test), but the US tax code considers IRL2 an Irish company (uses the registration test). Neither taxes it. Apple's subsidiary, ASI, behaved like it was IRL2, it was "managed and controlled" via ASI Board meetings in Bermuda, so Irish Revenue did not tax it.
The U.S. administration condemned Apple's Irish tax structures in the 2013 Levin–McCain PSI, [59] [60] [61] however, it came to Apple's defense when the EU Commission levied a €13 billion fine on Apple for Irish tax avoidance from 2004 to 2014, the largest corporate tax fine in history, arguing that Apple paying the full 12.5% Irish ...
Dutch Sandwich is a base erosion and profit shifting (BEPS) corporate tax tool, used mostly by U.S. multinationals to avoid incurring European Union withholding taxes on untaxed profits as they were being moved to non-EU tax havens (such as the Bermuda black hole). These untaxed profits could have originated from within the EU, or from outside ...
The FDII tax regime gives US-based "intellectual property" ("IP") a low-tax 13.125% rate. The GILTI tax regime places a penalty on foreign-based IP (i.e. like in Ireland) that brings its effective rate above the FDII rate (i.e. incentivizes re-location of IP to the US). Experts believe that the TCJA neutralises Ireland's "multinational tax ...
In Ireland, tax credits reduce the amount of Irish income tax that a taxpayer pays in a given year. A few tax credits are granted automatically, while others can be claimed, either by simple notification to Revenue, or by completing a form. All tax credits are expressed as an annual amount. All are non-refundable.
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force (paid 50% of Irish salary tax), and created 57% of Irish OECD non-farm value-add.
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