Tax haven-ireland- Attac Ireland ESU presentation-Paris, 2014
1 like442 views
際際滷s from the presentation by Attac Ireland at the Attac European Summer University, Paris, Aug 2014
Tax haven-ireland- Attac Ireland ESU presentation-Paris, 2014
- 7. Over the last quarter of a century something fundamental seems to have changed in the way in which capitalism works. The tendency since 1970 has been towards greater geographical mobility of capital.
- 12. Pot of gold or Fools Gold? Richard Murphy Taxa:on of subsidiary companies allows royal:es to be paid to subsidiary companies resident in tax havens, avoids residence basis for taxa:on Taxa:on of dividends dividends from tax haven subsidiaries oCen received tax-足free by the parent company in Ireland Thin capitalisa:on financing of subsidiary ac:vity through intra-足group loans rather than capitalisa:on, and manipula:on of interest rates to receive tax relief Corporate secrecy secrecy jurisdic:on that undermines the regula:on of another domain Light touch regula:on of transfer pricing two or more companies that are part of the same parent company trade with and loan to each other
- 14. In 2009/10, Ireland had inward investment of $31.1bn. Outward investment in that period was $31.0bn. In other words, Ireland is not the loca:on in which foreign direct investment is taking place (Murphy, 2011: 11)
- 37. The Double Irish The intellectual property (IP) of companies such as Google, Apple, Facebook are registered in subsidiary companies in Ireland. For example, Google Ireland Ltd. is the Irish subsidiary of Google Inc.
- 38. 則 Google Ireland Ltd. makes all its money through selling ads 則 If a person in Germany buys an ad, the sale is recorded in Ireland 則 Royal:es from this sale accrue to Google Ireland Ltd.
- 39. However Irish law only recognises a company as being tax resident in Ireland if its main centre of business is in Ireland. So another Irish company is established in a tax haven such as Bermuda (the double Irish) E.g. Google Inc. established Google Holdings Ltd. in Bermuda
- 40. 則 Management team based in Google Holdings Ltd, Bermuda 則 Google Ireland Ltd pays royal:es to Google Holdings Ltd. 則 Bermuda 0% corpora:on tax. 則 Avoid paying tax in Dublin
- 42. Sincere thanks to Conor McCabe for sharing his research on the IFSC and for assis:ng with the prepara:on of this presenta:on.