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Ireland and corporate tax avoidance
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Cody Pomeray wrote: »what legal basis would the IRS have for coming after a subsidiary firm which is incorporated in Ireland, owned by a parent firm incorporated in Ireland, and managed and controlled outside of the US? Seriously.
Looks like you missed it, under US law the IRS has the power to levy taxes on all worldwide income of a company that is registered in the US including any subsidiaries.0 -
Cody Pomeray wrote: »Maybe don't start a paragraph with "look" if the rest of that paragraph is reliant on emotions and no facts.
Maybe don’t accuse others of relying on “emotions and no facts” if the best you can do is to encourage us to “read between the lines”.Cody Pomeray wrote: »The integrity of the 'arms length' rule and counterparty documentation requirements are the issues which make the Irish transfer pricing rules easy to overcome and an aberration in international tax law; I don't know of any law firm who would explicitly state this, but you can read between the lines in reports like this from Arthur Cox...0 -
The poster was looking for specific information on the arms length provisions of the Finance Act and how it compares internationally. Short of telling him/her to buy a couple of kgs of a textbook on Tax Law, it's the best anyone can offer.Maybe don’t accuse others of relying on “emotions and no facts” if the best you can do is to encourage us to “read between the lines”.0 -
Don't think so. Some of the political blustering is because Apple don't contribute enough to campaign warchests. Other companies that contribute are not getting hit to the same level.
Once Apple play ball and grease some palms, they'll be off the hook and life will go on.
One can be cynical given what happened after the recent financial crisis i.e. no major changes on Wall Street or prosecutions.
However I do detect a general cultural shift and society shift and a push back against corporations. Even some corporate executives have joined this side of the debate.0 -
Nobody denies that the US could institute laws or regulations which would be grievous to commercial interests of US corporations and would unreasonably interfere with corporations incorporated and active in foreign jurisdictions, having any relationship at all to a US parent firm.antoobrien wrote: »Looks like you missed it, under US law the IRS has the power to levy taxes on all worldwide income of a company that is registered in the US including any subsidiaries.
The point is, well, this would be excessive and damage trade.
That's why I said most advanced countries understand these limitations, and co-operate with one another. Most countries, that is, except Ireland and Holland. We are the guys who are outside the fold here, we need to stop presenting this as nothing to do with us.0 -
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Imagine a plumber in Dublin set up an off the shelf company in Switzerland, all his jobs were paid to that company and he gave himself minimum wage in order to pay as little tax as possible, house car etc owned by the offshore co. That loophole would be shut down quick smart.
Yeah I call the services you describe as tokenism or more like public relations/marketing, bet they get tax relief on them as well. A crack down on tax havens would probably be bad for Ireland though agree, still doesn't mean we have to pimp our country out to them. A Europe wide solution to the issue seems required. Isn't that on the agenda for the G8?
The plumber in Dublin is a lot different to the Googles and Amazons of this world on many levels and isn't a great comparison.
There's a tonne of creative accounting going on in the biggest companies in the world. They pay accountants, solicitors, specialist's, CFO's CEO's etc a lot of money to ensure they pay as little money as legally possible in taxes etc. They have the budgets and turnover to do it.
The "open market" and taxation policies across the globe have allowed them to become even more efficient in this area.
And of course for the likes of Google/Apple/Intel and the numerous medical and pharma organisations here, one does have to ask whether the jobs provided is a good enough pay off for the little corpo tax paid. There are many companies however who have very few staff here that funnel all their figures through here however.
The ONLY way to tackle the issue from a moral standpoint is to harmonise tax rates and eliminate and "offshore" havens. That is never going to happen however and just as well for us.0 -
Cody Pomeray wrote: »Most countries, that is, except Ireland and Holland. We are the guys who are outside the fold here, we need to stop presenting this as nothing to do with us.
And the UK & Berumuda.
And the US state of Delaware, where the a sizeable number of US companies are incorporated.0 -
Bermuda, absolutely.antoobrien wrote: »And the UK & Berumuda.
And the US state of Delaware, where the a sizeable number of US companies are incorporated.
Are you suggesting that the UK is a brassplate haven on the scale of Ireland for the avoidance of tax?
I'm still waiting for an answer to my question. You're suggesting that the US authorities take statutory or regulatory measures to call in foreign firms' tax obligations which the US understand to be substantively American.
Can you suggest how the US could do this without completely destroying legitimate cost sharing arrangements, tax treaties, and co-operation, especially between or within large international corporations where research and development activities are concerned?
It's just unbelievable. Nobody could seriously be proposing that level of intervention, but i'd like to see somebody attempt it. Do you have an answer?0 -
The way I see it is this has actually very little about avoiding US tax and is actually 99% related to avoiding EU taxes!
Therefore it is the EU laxity in this regard that is the problem. It is EU governments that are losing their tax revenue hand over fist, not the US.
Whether or not US multinational companies repatriate overseas earned profits is a separate matter. It's ironic that it is the US senate that is opening up this can of worms rather than other EU governments per se.0 -
Cody Pomeray wrote: »I'm still waiting for an answer to my question. You're suggesting that the US authorities take statutory or regulatory measures to call in foreign firms' tax obligations which the US understand to be substantively American.
Can you suggest how the US could do this without completely destroying legitimate cost sharing arrangements, tax treaties, and co-operation, especially between or within large international corporations where research and development activities are concerned?
All the US have to do is undo a couple of loopholes that the senate committee described as "tick box reporting" that allows them to vastly write down the amount of income that is attributable to US sources in favour of overseas sources, taking them out of the reach of the IRS. If you'd actually listened to the senate hearing recording and what those two idiots Levin & McCain said, instead of taking the torygraph and gurd'n as holy writ, you'd understand this.
As for the Transfer pricing agreements, every company (not just the US ones) that files with the SEC (anyone that sells shares on a US stock exchange) has to register the agreements with the SEC. They can fix a lot of their perceived problems if they wish by stopping the practice of treating patents held by a company(group) in the same fashion as patents held by third parties (this is part of what Apple & Google do).
Of course they'd be as nuts to do that as we and the dutch would be to do anything without an international treaty that is binding on all UN members.0 -
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I'm basing this on my knowledge of tax law, I didn't watch the Senate hearings and I don't read the Telegraph or the Guardian.antoobrien wrote: »All the US have to do is undo a couple of loopholes that the senate committee described as "tick box reporting" that allows them to vastly write down the amount of income that is attributable to US sources in favour of overseas sources, taking them out of the reach of the IRS. If you'd actually listened to the senate hearing recording and what those two idiots Levin & McCain said, instead of taking the torygraph and gurd'n as holy writ, you'd understand this.
So be specific.
How do you suggest the US cracks down on Code 367 as it relates to firms' cost sharing arrangements as a way of "closing a loophole", without grievously damaging US firms ability to co-operate with worldwide firms including those MNC subsidiaries pursuing a legitimate business in research and development here in Ireland?
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Cody Pomeray wrote: »How do you suggest the US cracks down on Code 367 as it relates to firms' cost sharing arrangements as a way of "closing a loophole", without grievously damaging US firms ability to co-operate with worldwide firms including those MNC subsidiaries pursuing a legitimate business in research and development here in Ireland?
I've already given you that answer.0 -
No you haven't. I'd like to be specific. Tell me how you would reform that code without grievously damaging Irish and American business interests.antoobrien wrote: »I've already given you that answer.
This is important because you are painting this as a problem of US laws - show us where you would tighten the law then.0 -
Cody Pomeray wrote: »No you haven't. I'd like to be specific. Tell me how you would reform that code without grievously damaging Irish and American business interests.
Yes I have. The tax dodge that google do is nothing to do with R&D.0 -
I'm not interested in individual companies; I'm talking about the tax law of both jurisdictions. It's a simple question. The exceptions allowed under strict, but reasonable and necessary cost sharing rules allow US firms to co-operate, develop or otherwise collaborate with subsidiary or otherwise related firms outside of the federal tax jurisdiction; however, because of the rules on the Irish side, these exceptions can be abused.antoobrien wrote: »Yes I have. The tax dodge that google do is nothing to do with R&D.
Now, most people see the exceptions under Code 367 as reasonable and would view any tightening of these regulations as excessively damaging to commercial interests on both sides.
However, you and Eamon Gilmore are two of the unusual cases.
Please, tell us how you would tighten this code without damaging irish interests.0 -
Cody Pomeray wrote: »Now, most people see the exceptions under Code 367 as reasonable and would view any tightening of these regulations as excessively damaging to commercial interests on both sides.
That very much depends on which part of it you're nitpicking. If they tightened up on the abusive transfers of patents (IP transfers is covered under intangibles) it wouldn't cost Ireland much - because the TPAs on these is used to transfer income out of Ireland before they pay tax on it here.
Perhaps if Code 637 is tightened up we'll see more companies doing what Alkermes did when they merged with/bought out Elan and bring their corporate HQ here.0 -
Oh ha, good one! By that rationale, Holland and Ireland should be the ones taking an initiative of tightening/ creating and enforcing our anti deferral and TP rules, and watch all the US corporations just file in !antoobrien wrote: »Perhaps if Code 637 is tightened up we'll see more companies doing what Alkermes did when they merged with/bought out Elan and bring their corporate HQ here.
You're really over egging the pudding on this one.0 -
Cody Pomeray wrote: »Oh ha, good one! By that rationale, Holland and Ireland should be the ones taking an initiative of tightening/ creating and enforcing our anti deferral and TP rules, and watch all the US corporations just file in !
That's exactly the opposite of what I'm suggesting.0 -
I'm using your rationale. You're avoiding the ineascapable fact that tightening US tax rules for the obligations of subsidiaries or related firms incorporated in Ireland would damage Irish interests by implying that such tightening could actually be good for the Irish economy.
That's clearly BS. If it had any credibility, we would be closing down the loopholes we have carefully built in order to lure more corporations into our tax net. It's delusional stuff.0 -
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Cody Pomeray wrote: »I'm using your rationale. You're avoiding the ineascapable fact that tightening US tax rules for the obligations of subsidiaries or related firms incorporated in Ireland would damage Irish interests by implying that such tightening could actually be good for the Irish economy.
It's only an inescapable fact if you buy into the belief that the only reason that US companies are here is for corporation tax, which is plainly not the case. The fact of the matter is that most US companies pay very little CT in Ireland, however many have substantial operations. Closing US tax loopholes will not change the significance of European operations centers to these companies.
Now I don't now what rationale you think I'm using, but I've given you one clear case of a US company relocating its corporate HQ to an Irish operation. Are you suggesting that companies that go to such lengths as to set up complex TPAs will not relocate their corporate operations to somewhere that is more tax beneficial, especially considering the US can not change double taxation rules without seriously damaging themselves?0 -
Relocate in the event of what? A North Korean style tax regime in the US? The abrogation of its tax treaties? Certainly, if the US corporations are taxed out of existence they will rise from the ashes in offshore tax havens and onshore tax havens in other corporate personages. This is not a very illuminating statement. Not least because nobody really considers that likely or reasonable.antoobrien wrote: »I've given you one clear case of a US company relocating its corporate HQ to an Irish operation. Are you suggesting that companies that go to such lengths as to set up complex TPAs will not relocate their corporate operations to somewhere that is more tax beneficial
In reality, the US authorities would first broaden the base by tightening rules on CFCs and deferral to an unreasonable extent, and in the process, lure US corporations back into the US tax jurisdiction. That is a result that is in danger of occurring due to (i) aggressive tax competition and (ii) offering an irresponsible profit manipulation mechanism in collaboration with tax havens. Ireland is guilty on both counts.
Nobody wants that to happen. Not even the greenest of the green jersey brigade. Tightening anti deferral, TP, and cost-sharing rules are a terrible idea for legit corporations pursuing business interests outside the US. Exceptions to US federal tax obligations exist for very good reason, but there is a good amount of wiggle room there for the US to make decisions that are completely against Irish interests, especially as it relates to intangible property and our vision of Ireland as an R&D hub.
And all for what? Losing innovative corporations that actually create employment in Ireland, who pay Irish taxes... to save brassplates paying very little?
I believe we will clean up our tax system and rid ourselves of a profit manipulation loophole that is of no serious benefit to the Irish economy. Hopefully we will start actually engaging in the promotion of genuinely productive enterprise around the same time. That might be helpful.0 -
Cody Pomeray wrote: »I'm not interested in individual companies; I'm talking about the tax law of both jurisdictions. It's a simple question. The exceptions allowed under strict, but reasonable and necessary cost sharing rules allow US firms to co-operate, develop or otherwise collaborate with subsidiary or otherwise related firms outside of the federal tax jurisdiction; however, because of the rules on the Irish side, these exceptions can be abused.
Now, most people see the exceptions under Code 367 as reasonable and would view any tightening of these regulations as excessively damaging to commercial interests on both sides.
However, you and Eamon Gilmore are two of the unusual cases.
Please, tell us how you would tighten this code without damaging irish interests.
Cody, you have a little bit of knowledge, which is a dangerous thing!
How do you expect Ireland to tax a company that is not tax resident in Ireland?
The United States is one of the very few territories who do not tax companies who are managed and controlled in that country.
In the example of nowhere resident Apple, if they were managed in UK, they'd be taxed in the Uk, managed in Ireland - taxed in Ireland, managed in Germany - taxed in Germany. Its not Ireland's fault that the US chooses to tax by incorporation.
The Apple model of "resident nowhere" is actually very rare, because for one thing it looks terrible.
The Google model of using companies managed and controlled in an offshore haven is much more common. But again this is completely facilitated by the US. The US company sells its IP to the Haven company. The IRS audit this and agree the valuation, and the amount is fully taxable in the US. The Haven resident company then licenses the IP to other territories, including Ireland, for amounts in accordance with OECD international tax rules and these are received tax-free.
If the IP was still located in the US, the Irish subisidary would have to pay royalties to the US, but because the IP is now in the haven, Ireland has to pay royalties to it instead. Its not Ireland's fault that the US allowed the IP to be transferred out of the US, and not Ireland's fault that the Haven territory chooses not to tax anyone.
We have our 12.5% rate, a legitimate, transparent tax rate. ALL profits earned by Irish resident companies are taxed at this rate.0 -
Cody Pomeray wrote: »The integrity of the 'arms length' rule and counterparty documentation requirements are the issues which make the Irish transfer pricing rules easy to overcome and an aberration in international tax law; I don't know of any law firm who would explicitly state this, but you can read between the lines in reports like this from Arthur Cox, which gives a fairly good breakdown of the Finance Act 2010.
http://www.arthurcox.com/uploadedFiles/Publications/Publication_List/Arthur%20Cox%20-%20The%20New%20Irish%20Transfer%20Pricing%20Regime,%20April%202010.pdf
The Finance Act was an amazing creature. Although it claimed to 'tighten' Irish transfer pricing rules, as Arthur Cox point out, the rules were very much "light touch". But even more absurdly, the Act actually further relaxed irish provisions on dividends and royalties. In international tax law, our provisions on transfer pricing remain, therefore, exceptional.
Utter nonsense!!
As outlined in the Arthur Cox document, Ireland's transfer pricing legislation represents Ireland formally adopting both the OECD Transfer Pricing Guidelines and the “arm’s length” principle.
To say Ireland's TP rules are an "aberration in international tax law" is just simply a lie.
The "light touch" reference in Arthur Cox document is around the administrative requirements, not that it can be ignored! Companies have to spend a fortune in advisors fees in preparing transfer pricing studies and benchmarking analyses to support their intercompany pricing.
Ireland has two aspects which are lighter than other jurisdictions, which helps avoid companies incurring unnecessary expense. First of all, we accept TP studies performed in other countries, so long as Ireland is referenced in those studies (other countries require new full TP studies, regardless of the fact that a study has already been carried out, resulting in a duplication of work and fees).
Ireland also does not care if the Irish sub has underpaid (for example) a royalty expense - because this means Ireland is receiving additional tax. This would never happen with royalties paid to OECD countries, because their TP will ensure that Ireland does not underpay (thus again a duplication of studies/fees is eliminated).
You're also talking nonsense on Ireland's provisions re royalties and dividends. The likes of UK and Netherlands have a more favourable treatment of royalties and dividends and we are trying to bring ours more in line, but we're not there yet - for example foreign dividends received are completely exempt from tax in UK and NL, but that's not the case in Ireland.0 -
The Rooster wrote: »Utter nonsense!!The Rooster wrote: »just simply a lie
Okay first of all - sit down and spare us the affected indignation. Even for someone who is interested in taxation, this is hardly so impassioned a topic as your offence would suggest - lets deal calmly with whatever arguments you are trying to make.The Rooster wrote: »You're also talking nonsense
Well, everyone knows that the Finance Act 2010 (officially) introduced the arms length principle for the transactions under discussion, and that this is broadly correspondent with the OECD framework. What is at issue is the extent of monitoring and enforcement relative to other EU tax jurisdictions, you see.As outlined in the Arthur Cox document, Ireland's transfer pricing legislation represents Ireland formally adopting both the OECD Transfer Pricing Guidelines and the “arm’s length” principle.
One concern is lax documentation requirements compared to, say the UK. Another more important example is that provision whereby it may be made unduly burdensome to try and take a case against the companies operating suspect transfer pricing arrangements in this jurisdiction as a result of the grandfathering provision of the legislation.
A breakdown by Matheson Ormsby is available here
http://hb.betterregulation.com/external/How%20to%20be%20sure%20your%20transfer%20pricing%20arrangements%20in%20Ireland%20are%20grandfathered.pdf
This is in stark contrast to other EU countries also operating broadly in accordance with the OECD framework, where in fact the trend is toward tightening transfer pricing rules and aggressive tax avoidance mechanisms. Do you deny this? Are you aware of Germany, France, Belgium and Spain tightening their TP rules... are you aware of even the Netherlands doing so? This is what I say when I describe Ireland as aberration.
We created a half assed regulation and then stuck in a heap of other goodies for high paid CEOs to come here and pay less tax on their salaries to sweeten the deal. Like I said, two fingers.0 -
Cody Pomeray wrote: »Well, everyone knows that the Finance Act 2010 (officially) introduced the arms length principle for the transactions under discussion, and that this is broadly correspondent with the OECD framework. What is at issue is the extent of monitoring and enforcement relative to other EU tax jurisdictions, you see.
One concern is lax documentation requirements compared to, say the UK. Another more important example is that provision whereby it may be made unduly burdensome to try and take a case against the companies operating suspect transfer pricing arrangements in this jurisdiction as a result of the grandfathering provision of the legislation.
A breakdown by Matheson Ormsby is available here
http://hb.betterregulation.com/external/How%20to%20be%20sure%20your%20transfer%20pricing%20arrangements%20in%20Ireland%20are%20grandfathered.pdf
This is in stark contrast to other EU countries also operating broadly in accordance with the OECD framework, where in fact the trend is toward tightening transfer pricing rules and aggressive tax avoidance mechanisms. Do you deny this? Are you aware of Germany, France, Belgium and Spain tightening their TP rules... are you aware of even the Netherlands doing so? This is what I say when I describe Ireland as aberration.
We created a half assed regulation and then stuck in a heap of other goodies for high paid CEOs to come here and pay less tax on their salaries to sweeten the deal. Like I said, two fingers.
Our TP rules are in accordance with OECD principles. Any transactions relating to a trade with related parties must be for an arm's length amount. It can't be any tighter than that!
We are less burdensome in respect of paperwork, but only to the extent that there is existing paperwork in place that we can piggyback on. If there is not, then our requirements are very similar to the UK's.
The grandfathering is a transitional arrangment so there was no "big bang" for companies. But Revenue made it very clear in their statement of practice that it is short lived. For example a royalty agreement loses it grandfathered status when there is a change in products covered by the agreement (even if there has been no change to the agreement itself). So tech companies with ever evolving product ranges will benefit from grandfathering for at most a year or so.
Absolute nonsense to say Revenue are not monitoring it. Another statement you need to retract.
There is very little in the way of income tax incentives for high paid foreign CEOs, we're well behind our competitiors in that regard. I wish we did have a "heap of goodies" that would attract high paid foreign CEOs (and all the additional employment they would bring with them).0 -
This is becoming something of a mantra.The Rooster wrote: »Our TP rules are in accordance with OECD principles.
The OECD principles can be described as a broad framework - it would be incorrect to portray it as a harmonised regulatory structure; within that OECD framwork, Ireland delivers more lax environment than the countries I mentioned, whereby in those countries the trend is toward tighening TP rules to an extent not yet envisaged in Ireland.
No, because that is my understanding of how things operate.Absolute nonsense to say Revenue are not monitoring it. Another statement you need to retract.
Oh please, a 30% reduction in income tax for the relevant income, to put that into context, someone on €500,000 is automatically *entitled* to an income tax relief disregard of €130,000, and that's before you start to apply additional write-offs for sending his kids to private schools abroad and holidays home... meanwhile in the real world...There is very little in the way of income tax incentives for high paid foreign CEOs, we're well behind our competitiors in that regard. I wish we did have a "heap of goodies" that would attract high paid foreign CEOs (and all the additional employment they would bring with them).
How many EU countries are more generous than this?0 -
Learn to read the accounts properly.
(www.duedil.com - free reg, you can get any companies accounts from here)
Google Ireland Limited 2011:
Turnover 12,457,352,000 EUR
Cost Of Sales 3,382,094,000 EUR
Gross Profit 9,075,258,000 EUR
Operating Profit 20,852,000 EUR
Pre-Tax Profit 24,369,000 EUR
Post-Tax Profit 2,153,000 EUR
As you can see, "profit" can refer to lots of different stuff. That 9 billion gross profit is not what is taxable. You have made the same mistake with the other companies too.
The discrepancy is caused by transfer pricing rules, as allowed by the USA via tax treaties with various countries.
They are still immoral.
Please post the full figures for all your favorite tax dodging companies.Mitch Hedberg: "Rice is great if you're really hungry and want to eat two thousand of something."
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Care to explain how any country can tighten the rules re arm's length?Cody Pomeray wrote: »The OECD principles can be described as a broad framework - it would be incorrect to portray it as a harmonised regulatory structure; within that OECD framwork, Ireland delivers more lax environment than the countries I mentioned, whereby in those countries the trend is toward tighening TP rules to an extent not yet envisaged in Ireland.
The rules are indentical in most countries, i.e. they all follow the OECD principles. Ireland allows companies to piggy back on other countries documentation. That's the main difference, along with the temporary grandfathering difference.
Well your understanding is 100% wrong. Revenue have been active in hiring and training staff over the last 2 years to perform TP audits.Cody Pomeray wrote: »No, because that is my understanding of how things operate.Cody Pomeray wrote: »Oh please, a 30% reduction in income tax for the relevant income, to put that into context, someone on €500,000 is automatically *entitled* to an income tax relief disregard of €130,000
We have a Special Assignee Relief Program, which was brought in by FG/Lab at the request of the IDA in order to make Ireland more attractive for foreign direct investment, and so we can compete against the incentives offered by the likes of Switzerland, Netherlands, Luxembourg. Its not automatic, there are a number of onerous conditions to be met.
But if we did attract a foreign CEO over who was on €500,000, and who did meet all the conditions for the SARP, then he would "only" contrbute €180,000 to the Irish Exchequer. Which is €180,000 more than we'd get if he chose to move to Switzerland instead. Plus these guys don't come and sit in an office by themselves, they hire people - which means more revenue for the Irish exchequer and less money paid out in social welfare.
Its beyond ridiculous how anyone could criticise this. The IDA are one government agency who consistently (under all colours of goverment) perform great work in attracting multi nationals to Ireland and all the jobs that come with that.0 -
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They are still immoral.
Please post the full figures for all your favorite tax dodging companies.
Whether Google (or any other company) earning profits in offshore havens, who choose not to tax such profits, is immoral is a question for shareholders and customers of said company.
But its nothing to do with Ireland.
If Google had picked UK, Netherlands, Switzerland as their HQ in Europe, that country would pay the exact same royalties out to the tax haven.
If the US tax rules had not allowed Google to transfer its IP from US to the haven, the HQ company would still have to pay royalties to the US instead of to the haven.
Ireland is doing absolutely nothing wrong, so the criticism it get is ridiculous. I can understand the US and UK politicians as they are playing to their electorate, but for Irish people to be critical of our tax policies that attract the MNCs is pure gombeenism.
Google employs over 2,000 people in Ireland, and contributes north of €70M a year in corporate tax and payroll taxes to the Irish exchequer.
We have a 12.5% tax rate that applies to all profits properly attributable to Irish operations, in accordance with international tax law. Completely transparent, and we don't do under the table deals like they do in Lux and Switzerland.0
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