Base erosion and profit shifting (OECD project)

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"It is hard to imagine any business, under the current [Irish] IP regime, which could not generate substantial intangible assets under Irish GAAP that would be eligible for relief under [the Irish] capital allowances [for intangible assets scheme]." "This puts the attractive 2.5% Irish IP-tax rate within reach of almost any global business that relocates to Ireland."

Contents

KPMG, "Intellectual Property Tax", 4 December 2017 [1]

Of the wider tax environment, O'Rourke thinks the OECD base-erosion and profit-shifting (BEPS) process is "very good" for Ireland. "If BEPS sees itself to a conclusion, it will be good for Ireland."

Feargal O'Rourke CEO PwC (Ireland)
"Architect" of the double Irish [2] [3]
The Irish Times, 2015 [4]

The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD/G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using base erosion and profit shifting tools. [5] The project, led by the OECD's Committee on Fiscal Affairs, began in 2013 with OECD and G20 countries, in a context of financial crisis and tax affairs (e.g. Offshore Leaks). [6] Currently, after the BEPS report has been delivered in 2015, the project is now in its implementation phase, 116 countries are involved including a majority of developing countries. [7] [8] During two years, the package was developed by participating members on an equal footing, as well as widespread consultations with jurisdictions and stakeholders, including business, academics and civil society. And since 2016, the OECD/G20 Inclusive Framework on BEPS provides for its 140 members a platform to work on an equal footing to tackle BEPS, including through peer review of the BEPS minimum standards, and monitoring of implementation of the BEPS package as a whole.

The BEPS project looks to develop multilateral dialogue and could be achieved thanks to a successful international cooperation, unavoidable when it comes to such a domestic and sovereign topic. [9] [10] It is one of the instances of the OECD that involves developing countries in its process. [11] The European Commission and the US have unilaterally [12] taken actions in 2017-2018 that implement several key measures of the BEPS project, even going beyond in some cases.

Content

Project aim

The aim of the project is to mitigate tax code loopholes and country-to-country inconsistencies so that corporations cannot shift profits from a country with a high corporate tax rate to countries with a low tax rate. The practice - in particular double non-taxation - is usually legal but often involves complex manoeuvres within tax law. BEPS is costly for all parties involved, save the firm. The citizens' trust in tax systems can be harmed by widespread tax avoidance practices, which puts at stake fiscal consent a concept at the core of modern democracies ; it is also a loss of revenues for the State. A conservative estimate has annual tax revenue losses between 100 and US$240 billion (i.e. 4-10% of global revenues from corporate income tax) due to profit shifting around the globe. [6] A study by the Tax Justice Network estimated that around US$660 billion of corporate profits were shifted in 2012. [13] In developed countries like those comprising the OECD, BEPS undermines the integrity of tax systems. In developing countries, where there is heavy reliance on corporate taxes, revenues are trimmed, leaving states underfunded and underinvested. [14]

Furthermore, the project serves as an alternative to the deterioration of international tax norms. The project's Action Plan states that a failure to address BEPS would spawn "the emergence of competing sets of international standards, and the replacement of the current consensus-based framework by unilateral measures, which could lead to global tax chaos marked by the massive re-emergence of double taxation. [14] In this respect, the BEPS project serves as an example of cooperation in game theory. The project prevents both double taxation and double non-taxation, as well as countries undercutting others by lowering tax rates to attract business. Countries cooperating yields a better outcome than non-cooperation.

Inclusive Framework

In October 2015, after two years of negotiations and development, a 15-point Action Plan was announced by the OECD and G20 to address BEPS. [6] The Inclusive Framework was established in 2016, it was deemed necessary that for an effective international tax framework, developing countries must be involved. [15] To gain membership, non-OECD/G20 countries must commit to the BEPS package, a plan to "equip government with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created." [16] All countries in the framework work on equal footing to implement the BEPS package. The package consists of 15 action plans that provide tax standards in exchange for a membership fee (discounted for developing countries). As of May 2018, 116 countries had signed on to the project. [17]

BEPS achievements

During its ongoing implementation and as of July 2018, the BEPS project of the OECD allowed to achieve the following realisations:

BEPS examples

A spate of BEPS scandals in the past decade has served as an impetus for the OECD's action. The largest firms are often U.S. multinationals avoiding the high (35%) worldwide corporate tax rate in the United States. However BEPS tools (and structuring) are also increasingly used in money laundering/regulatory avoidance. The following are prominent examples of the leading BEPS tools in operation today:

  1. Double Irish is a BEPS scheme used by U.S. corporations in Ireland (incl. Apple, [19] [20] [21] [22] Google [23] [24] and Facebook [25] [26] [27] [28] ), [29] to shield non-U.S. income from the pre TCJA U.S. worldwide 35% tax system, [30] [31] and almost all Irish taxes. [32] As the BEPS scheme used to build offshore reserves of $1 trillion, [33] [34] it is the largest tax avoidance structure in history. [35]
  2. Single malt is another BEPS tax scheme designed to replicate the double Irish, which is impossible after 2020. [36] [37] It relies on specific wording in bi-lateral Irish tax treaties (particularly with Malta and the United Arab Emirates) to re-create the double Irish system and its effective tax rate of <1%. Single malt is used by Microsoft and Allergan in Ireland. [38] [39]
  3. Capital allowances for intangible assets is Ireland's long-term replacement for double Irish and single malt. It delivers an effective tax rate of 0-3%. When Apple, the largest user of BEPS tools globally, restructured its controversial double Irish subsidiary in 2015 (as agreed with the EU Commission), it chose the capital allowances for intangible assets scheme. [40] [41] Accenture used it in 2009. [42]
  4. Corporate tax inversions are the original BEPS tools. Despite most activity being in the U.S., heavy machinery manufacturer Caterpillar Inc. shifted profits to Switzerland, where its effective tax rate was 4-6%, saving $2.4 billion from 2002-2012. [43] By combining the capital allowances for intangible assets scheme with an Irish corporate tax inversion, Ireland has become the leading destination for U.S. firms. [44]
  5. Securitization SPVs are an emerging new BEPS tool. Structures such as the Section 110 SPV are being used to create more advanced artificial loan structures, which are harder to understand and prevent, for BEPS-type activities (including money laundering/regulatory avoidance purposes). There has been a material uplift in Section 110 SPVs by sanctioned Russian financial institutions.

Structure

The BEPS project consists of 15 action plans with 4 minimum standards, agreed to by all participating countries who have committed to consistent implementation.

Some measures can be used immediately, others require renegotiating bilateral tax treaties. [45]

Action 1: Address the Digital Economy

Action 2: Hybrids

Action 3: Controlled Foreign Companies (CFC) Rules

Action 4: Interest Deductions

Action 5: Harmful Tax Practices (minimum standard)

Action 6: Treaty Abuse (minimum standard)

Action 7: Permanent Establishment Status

Actions 8-10: Transfer Pricing

Action 11: BEPS Data Analysis

Action 12: Disclosure of Aggressive Tax Planning

Action 13: Transfer Pricing Documentation (minimum standard)

Action 14: Dispute Resolution(minimum standard)

Action 15: Multilateral Instrument

Other initiatives

In 2017–2018, both the U.S. and the European Commission decided to depart from the OECD BEPS process and timetable, and launch their own anti-BEPS tax regimes:

The departure of the U.S. and EU Commission from the OECD BEPS project is attributed to frustrations with the rise in intellectual property (or IP), as a key BEPS tool to create intangible assets, which are then turned into royalty payment BEPS schemes (double Irish), and/or capital allowance BEPS schemes (capital allowances for intangibles). In contrast, the OECD has spent decades developing intellectual property as a legal and a GAAP accounting concept. [59]

Ireland, who has some of the most advanced IP-based BEPS tools in the world, [60] and have the first OECD-approved IP-box, [61] has been a supporter of the OECD BEPS project (see Feargal O'Rourke quote). [62] 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] [64] [65]

However, the U.S. and EU's new tax regimes deliberately "override" these IP-based BEPS tools. [66] [67] [54] [55] [56]

Ireland has opened a new line of Debt-based BEPS tools which use securitization vehicles to create advanced artificial loan structures that are hard to understand and track in the $10 trillion global securitisation sector [68] (the securitization orphan structure approach also hides their ownership). Main tool is the Section 110 SPV.

See also

Related Research Articles

Corporate haven, corporate tax haven, or multinational tax haven is used to describe a jurisdiction that multinational corporations find attractive for establishing subsidiaries or incorporation of regional or main company headquarters, mostly due to favourable tax regimes, and/or favourable secrecy laws, and/or favourable regulatory regimes.

Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length. The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative practice. Countries with transfer pricing legislation generally follow the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in most respects, although their rules can differ on some important details.

<span class="mw-page-title-main">Corporation tax in the Republic of Ireland</span> Irish corporate tax regime

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, and created 57% of Irish OECD non-farm value-add. As of 2017, 25 of the top 50 Irish firms were U.S.–controlled businesses, representing 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.

A permanent establishment (PE) is a fixed place of business that generally gives rise to income or value-added tax liability in a particular jurisdiction. The term is defined in many income tax treaties and in most European Union Value Added Tax systems. The tax systems in some civil-law countries impose income taxes and value-added taxes only where an enterprise maintains a PE in the country concerned. Definitions of PEs under tax law or tax treaties may contain specific inclusions or exclusions.

A tax haven is a term, sometimes used negatively and for political reasons, to describe a place with very low tax rates for non-domiciled investors, even if the official rates may be higher.

<span class="mw-page-title-main">Tax inversion</span> Corporate relocation to a lower tax location

A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in the original country. The US definition requires that the original shareholders remain a majority control of the post-inverted company. In US federal legislation a company which has been restructured in this manner is referred to as an "inverted domestic corporation", and the term "corporate expatriate" is also used.

<span class="mw-page-title-main">Offshore financial centre</span> Corporate-focused tax havens

An offshore financial centre (OFC) is defined as a "country or jurisdiction that provides financial services to nonresidents on a scale that is incommensurate with the size and the financing of its domestic economy."

<span class="mw-page-title-main">Double Irish arrangement</span> Irish corporate tax avoidance tool

The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement.

A patent box is a special very low corporate tax regime used by several countries to incentivise research and development by taxing patent revenues differently from other commercial revenues. It is also known as intellectual property box regime, innovation box or IP box. Patent boxes have also been used as base erosion and profit shifting (BEPS) tools, to avoid corporate taxes.

<span class="mw-page-title-main">Base erosion and profit shifting</span> Multinational tax avoidance tools

Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher-tax jurisdictions to lower-tax jurisdictions or no-tax locations where there is little or no economic activity, thus "eroding" the "tax-base" of the higher-tax jurisdictions using deductible payments such as interest or royalties. For the government, the tax base is a company's income or profit. Tax is levied as a percentage on this income/profit. When that income / profit is transferred to another country or tax haven, the tax base is eroded and the company does not pay taxes to the country that is generating the income. As a result, tax revenues are reduced and the government is disadvantaged. The Organisation for Economic Co-operation and Development (OECD) define BEPS strategies as "exploiting gaps and mismatches in tax rules". While some of the tactics are illegal, the majority are not. Because businesses that operate across borders can utilize BEPS to obtain a competitive edge over domestic businesses, it affects the righteousness and integrity of tax systems. Furthermore, it lessens deliberate compliance, when taxpayers notice multinationals legally avoiding corporate income taxes. Because developing nations rely more heavily on corporate income tax, they are disproportionately affected by BEPS.

<span class="mw-page-title-main">Dutch Sandwich</span> Dutch withholding tax avoidance tool

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. These untaxed profits could have originated from within the EU, or from outside the EU, but in most cases were routed to major EU corporate-focused tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich.

<span class="mw-page-title-main">Leprechaun economics</span> Term used to describe a distortion of Irelands GDP by Apple Inc restructuring

Leprechaun economics was a term coined by economist Paul Krugman to describe the 26.3 per cent rise in Irish 2015 GDP, later revised to 34.4 per cent, in a 12 July 2016 publication by the Irish Central Statistics Office (CSO), restating 2015 Irish national accounts. At that point, the distortion of Irish economic data by tax-driven accounting flows reached a climax. In 2020, Krugman said the term was a feature of all tax havens.

<span class="mw-page-title-main">Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting</span>

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, sometime abbreviated BEPS multilateral instrument, is a multilateral convention of the Organisation for Economic Co-operation and Development to combat tax avoidance by multinational enterprises (MNEs) through prevention of Base Erosion and Profit Shifting (BEPS). The BEPS multilateral instrument was negotiated within the framework of the OECD G20 BEPS project and enables countries and jurisdictions to swiftly modify their bilateral tax treaties to implement some of the measures agreed.

<span class="mw-page-title-main">Conduit and sink OFCs</span> Classification of tax havens

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<span class="mw-page-title-main">Apple's EU tax dispute</span> Tax dispute involving Apple, Ireland, and the EU

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<span class="mw-page-title-main">Modified gross national income</span> Metric to measure the Irish economy by excluding globalisation effects

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<span class="mw-page-title-main">Feargal O'Rourke</span> Managing Partner of PwC, Dublin

Feargal O'Rourke is an Irish accountant and corporate tax expert, who was the managing partner of PwC in Ireland. He is considered the architect of the Double Irish tax scheme used by U.S. firms such as Apple, Google and Facebook in Ireland, and a leader in the development of corporate tax planning tools, and tax legislation, for U.S. multinationals in Ireland.

<span class="mw-page-title-main">Ireland as a tax haven</span> Allegation that Ireland facilitates tax base erosion and profit shifting

Ireland has been labelled as a tax haven or corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic "tax haven lists", including the § Leaders in tax haven research, and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.

Dhammika Dharmapala is an economist who is the Paul H. and Theo Leffman Professor of Law at the University of Chicago Law School. He is known for his research into corporate tax avoidance, corporate use of tax havens, and the corporate use of base erosion and profit shifting ("BEPS") techniques.

<span class="mw-page-title-main">Global minimum corporate tax rate</span> Proposed international tax scheme

The global minimum corporate tax rate, or simply the global minimum tax, is a minimum rate of tax on corporate income internationally agreed upon and accepted by individual jurisdictions in the OECD/G20 Inclusive Framework. Each country would be eligible for a share of revenue generated by the tax. The aim is to reduce tax competition between countries and discourage multinational corporations (MNC) from profit shifting that avoids taxes.

References

  1. ↑ "Intellectual Property Tax". KPMG. 4 December 2017.
  2. ↑ "Man Making Ireland Tax Avoidance Hub Proves Local Hero". Bloomberg News. 28 October 2013.
  3. ↑ "Controversial tax strategies brainchild of O'Rourke's son". Irish Independent . 3 November 2013.
  4. ↑ "Scion of a prominent political dynasty who gave his vote to accountancy". The Irish Times . 8 May 2015.
  5. ↑ "Base erosion and profit shifting - OECD". www.oecd.org. Retrieved 2017-05-22.
  6. 1 2 3 "BEPS Project Background Brief" (PDF). OECD. January 2017.
  7. ↑ "About BEPS and the inclusive framework - OECD". www.oecd.org.
  8. ↑ "Inclusive Framework of BEPS members" (PDF). www.oecd.org.
  9. ↑ Peter Dietsch (2011). "Rethinking sovereignty in international fiscal policy". Review of International Studies. 37 (5): 2107–2120. doi:10.1017/S0260210511000349. S2CID   145597440 . Retrieved 2018-07-25.
  10. ↑ "BEPS: An Interim Evaluation" (PDF). World Tax Journal.
  11. ↑ "The OECD´s New Role as a Global Institution". www.mfa.gov.tr. Retrieved 2018-07-25.
  12. ↑ "The US counterpunch to the OECD BEPS Project". aei.org. Retrieved 2018-07-25.
  13. ↑ "The scale of Base Erosion and Profit Shifting (BEPS) - Tax Justice Network". Tax Justice Network.
  14. 1 2 3 4 5 6 7 "BEPS Action Plan" (PDF). oecd.org.
  15. ↑ "Inclusive Framework Flyer" (PDF). www.oecd.org.
  16. ↑ "BEPS Actions - OECD". www.oecd.org.
  17. ↑ "Inclusive Framework on BEPS Composition" (PDF). oecd.org.
  18. 1 2 3 4 5 "G20 Report to Ministers 2018" (PDF). oecd.org.
  19. ↑ "Pinning Down Apple's Alleged 0.005% Tax Rate Is Nearly Impossible". Bloomberg News . 1 September 2016.
  20. ↑ Duhigg, Charles; Kocieniewski, David (28 April 2012). "How Apple Sidesteps Billions in Global Taxes". The New York Times . Retrieved 22 March 2018. In the late 1980s, Apple was among the pioneers in creating a tax structure – known as the Double Irish – that allowed the company to move profits into tax havens around the world
  21. ↑ "Senate Probe Finds Apple Used Unusual Tax Structure to Avoid Taxes". CNBC . Reuters. 20 May 2013. Retrieved 20 May 2013.
  22. ↑ "After a Tax Crackdown, Apple Found a New Shelter for Its Profits". The New York Times. 6 November 2017.
  23. ↑ "'Double Irish' and 'Dutch Sandwich' saved Google $3.7bn in tax in 2016". Irish Times. 2 January 2018.
  24. ↑ "Google's 'Dutch Sandwich' Shielded 16 Billion Euros From Tax". Bloomberg. 2 January 2018.
  25. ↑ "'Double Irish' limits Facebook's tax bill to €1.9m in Ireland". Financial Times . 5 December 2013.
  26. ↑ "Facebook paid just €30m tax in Ireland despite earning €12bn". Irish Independent. 29 November 2017.
  27. ↑ "Facebook Ireland pays tax of just €30m on €12.6bn". Irish Examiner . 29 November 2017.
  28. ↑ "Oracle paid just €11m tax on Irish turnover of €7bn". Irish Independent. 28 April 2014.
  29. ↑ "Ireland: Where Profits Pile Up, Helping Multinationals Keep Taxes Low". Bloomberg. 2014.
  30. ↑ "How to stop the inversion perversion". The Economist . 26 July 2014.
  31. ↑ "A Territorial Tax System Would Create Jobs and Raise Wages for U.S. Workers". The Heritage Foundation. 12 September 2013.
  32. ↑ "What is the Double Irish". Financial Times. 9 October 2014.
  33. ↑ "The real story behind US companies' offshore cash reserves". McKinsey & Company. June 2017.
  34. ↑ "US corporate giants hoarding more than a trillion dollars". The Guardian. 20 May 2016.
  35. ↑ "Apple vs the EU is the biggest tax battle in history". Time . 30 August 2016.
  36. ↑ "Multinationals replacing 'Double Irish' with new tax avoidance scheme". The Irish Independent. 9 November 2014.
  37. ↑ "Death of the "Double Irish Dutch Sandwich"? Not so Fast". Taxes Without Borders. 23 October 2014. Archived from the original on 22 March 2018. Retrieved 5 May 2018.
  38. ↑ "'Impossible' structures: tax outcomes overlooked by the 2015 tax Spillover analysis" (PDF). Christian Aid. November 2017.
  39. ↑ "Multinationals replacing 'Double Irish' with new tax avoidance scheme". RTE News. 14 November 2017.
  40. ↑ "What Apple did next". Seamus Coffey, University College Cork. 24 January 2014.
  41. ↑ "Tax Avoidance and the Irish Balance of Payments". Council on Foreign Relations. 25 April 2018.
  42. ↑ "Firm gets tax relief on $7bn rights: Accenture". Irish Examiner. 24 January 2012.
  43. ↑ United States Senate. "Caterpillar's Offshore Tax Strategy". senate.gov.
  44. ↑ "Tracking Tax Runaways". Bloomberg News. 1 March 2017.
  45. ↑ "BEPS - Frequently Asked Questions - OECD". www.oecd.org.
  46. 1 2 3 "BEPS Action Plan in a nutshell" (PDF). KPMG.
  47. ↑ "Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update - Inclusive Framework on BEPS - OECD". www.oecd.org.
  48. ↑ "Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report - OECD". www.oecd.org.
  49. ↑ "Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report - OECD". www.oecd.org.
  50. ↑ "Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report - OECD". www.oecd.org.
  51. ↑ "Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports - OECD". www.oecd.org.
  52. ↑ "Measuring and Monitoring BEPS, Action 11 - 2015 Final Report - OECD". www.oecd.org.
  53. ↑ "A Hybrid Approach: The Treatment of Foreign Profits under the Tax Cuts and Jobs Act". Tax Foundation. 3 May 2018.
  54. 1 2 "Trump's US tax reform a significant challenge for Ireland". The Irish Times. 30 November 2017.
  55. 1 2 "Donald Trump singles out Ireland in tax speech". The Irish Times. 29 November 2017.
  56. 1 2 "Why Ireland faces a fight on the corporate tax front". The Irish Times. 14 March 2018.
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  58. ↑ "What the EU's new taxes on the tech giants mean - and how they would hurt Ireland". TheJournal.ie . 24 March 2018.
  59. ↑ "New UN tax handbook: Lower-income countries vs OECD BEPS failure". Tax Justice Network. 11 September 2017.
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  61. ↑ "Do you know what the Knowledge Box is?". Irish Independent. 9 October 2015.
  62. ↑ "Maples and Calder Irish Intellectual Property Tax Regime - 2.5% Effective Tax". Maples and Calder Law Firm. February 2018.
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  64. ↑ "World IP Day: IRELAND'S 2.5% IP Tax Rate (Section 4.1.1)". Mason Hayes and Curran. April 2013.
  65. ↑ "Tax Legislation Changes Impacting the Financial Services Sector in…". mhc.ie. Mason Hayes & Curran. Retrieved 30 January 2024.
  66. ↑ "Inversions under the New Tax Law: Carrot and Stick". Tax Foundation. 13 March 2018.
  67. ↑ "Shake-up of EU tax rules a 'more serious threat' to Ireland than Brexit". Irish Independent. 14 September 2017.
  68. ↑ "Global Securitisation Market" (PDF). Morgan Stanley. 2017. Archived from the original (PDF) on 2018-03-17. Retrieved 2018-05-10.
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