Ireland as a tax haven
Allegation that Ireland facilitates tax base erosion and profit shifting / From Wikipedia, the free encyclopedia
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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.[lower-alpha 1][2] 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,[3] but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017.[4] Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist.[5] In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven.[6]
Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates § Effective tax rates of 0% to 2.5%[lower-alpha 2] on global profits re-routed to Ireland via their tax treaty network.[lower-alpha 3][lower-alpha 4] Ireland's aggregate § Effective tax rates for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit.[8][9] Ireland's tax-free QIAIF & L–QIAIF regimes, and Section 110 SPVs, enable foreign investors to avoid Irish taxes on Irish assets, and can be combined with Irish BEPS tools to create confidential routes out of the Irish corporate tax system.[lower-alpha 5] As these structures are OECD–whitelisted, Ireland's laws and regulations allow the use of data protection and data privacy provisions, and opt-outs from filing of public accounts, to obscure their effects. There is arguable evidence that Ireland acts as a § Captured state, fostering tax strategies.[11][12]
Ireland's situation is attributed to § Political compromises arising from the historical U.S. "worldwide" corporate tax system, which has made U.S. multinationals the largest users of tax havens, and BEPS tools, in the world.[lower-alpha 6] The U.S. Tax Cuts and Jobs Act of 2017 ("TCJA"), and move to a hybrid "territorial" tax system,[lower-alpha 7] removed the need for some of these compromises. In 2018, IP–heavy S&P500 multinationals guided similar post-TCJA effective tax rates, whether they are legally based in the U.S. (e.g. Pfizer[lower-alpha 8]), or Ireland (e.g. Medtronic[lower-alpha 8]). While TCJA neutralised some Irish BEPS tools, it enhanced others (e.g. Apple's "CAIA"[lower-alpha 9]).[19] A reliance on U.S. corporates (80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add), is a concern in Ireland.[lower-alpha 10]
Ireland's weakness in attracting corporates from "territorial" tax systems (Table 1),[lower-alpha 11] was apparent in its failure to attract material financial services jobs moving due to Brexit (e.g. no US investment banks or material financial services franchise). Ireland's diversification into full tax haven tools[lower-alpha 12] (e.g. QIAIF, L–QIAIF, and ICAV), has seen tax-law firms, and offshore magic circle firms, set up Irish offices to handle Brexit-driven tax restructuring. These tools made Ireland the world's 3rd largest Shadow Banking OFC,[24] and 5th largest Conduit OFC.[25][26]
Ireland has been associated with the term "tax haven" since the U.S. IRS produced a list on the 12 January 1981.[lower-alpha 13][28] Ireland has been a consistent feature on almost every non-governmental tax haven list from Hines in February 1994,[29] to Zucman in June 2018[30] (and each one in-between). However, Ireland has never been considered a tax haven by either the OECD or the EU Commission.[3][5] These two contrasting facts are used by various sides, to allegedly prove or disprove that Ireland is a tax haven, and much of the detail in-between is discarded, some of which can explain the EU and OCED's position. Confusing scenarios have emerged, for example:
- In April 2000, the FSF–IMF listed Ireland as an offshore financial centre ("OFC"), based on criteria which academics and the OECD support.[31] The Irish State has never refuted the OFC label, and there are Irish State documents that note Ireland as an OFC. Yet, the terms OFC and "tax haven" are often considered synonymous.[32][33][34]
- In December 2017, the EU did not consider Ireland to be a tax haven, and Ireland is not in the § EU 2017 tax haven lists; in January 2017 the EU Commissioner for Taxation, Pierre Moscovici, stated this publicly.[5] However, the same Commissioner in January 2018, described Ireland to the EU Parliament as a tax black hole.[27]
- In September 2018, the 29th Chair of the U.S. President's Council of Economic Advisors, tax-expert Kevin Hassett, said that: "It’s not Ireland’s fault U.S. tax law was written by someone on acid". Hassett, however, had labelled Ireland as a tax haven in November 2017, when advocating for the Tax Cuts and Jobs Act of 2017 ("TCJA").[35]
The next sections chronicle the detail regarding Ireland's label as a tax haven (most cited Sources and Evidence), and detail regarding the Irish State's official Rebuttals of the label (both technical and non-technical). The final section chronicles the academic research on the drivers of U.S., EU, and OCED, decision making regarding Ireland.
Ireland has been labelled a tax haven, or a corporate tax haven (or Conduit OFC), by:
- The main § Leaders in tax haven research:[36][37] James R. Hines Jr. (1994, 2007, 2010),[29][38][39] Dhammika Dharmapala (2008 and 2009),[40][41] and Gabriel Zucman (2013, 2014 and 2018);[8][30][32][42][43]
- Other important § Leaders in tax haven research:[36][37] Joel Slemrod (2006),[44] and Mihir A. Desai (2006);[45]
- Notable academic studies by the University of Amsterdam's CORPNET in 2017 (Conduit and Sink OFCs)[25][26] and by the International Monetary Fund journal in 2018;[46]
- Various academic tax-policy centres in Germany,[47] the United Kingdom,[48] the United Nations,[49] and Ireland itself;[50]
- The Institute on Taxation and Economic Policy[51][52] and Oxfam.[53][54] In 2021, the Tax Justice Network ranked Ireland 11th in its list of enablers of global corporate tax abuse after The British Virgin Islands, The Cayman Islands, Bermuda, The Netherlands, Switzerland, Luxembourg, Hong Kong, Jersey, Singapore, and The United Arab Emirates.[55] The Tax Justice Network estimates that Ireland facilitates US$16bn in taxes lost each year by other countries.[56]
- The two U.S. Congressional investigations into global tax havens: 2008 by the Government Accountability Office,[57] and 2015 by the Congressional Research Service.[58]
- The 2013 Levin–McCain U.S. Senate Permanent Subcommittee on Investigation ("PSI") into tax avoidance activities of U.S. multinationals by using "profit shifting" BEPS tools;[59][60][61]
- The books on tax havens in the last decade, with at least 300 citations on Google Scholar: Tax Havens: How Globalization Really Works, by Ronen Palan and Richard Murphy from 2010,[34] Treasure Islands: Tax Havens and the Men Who Stole the World, by Nicholas Shaxson from 2011, and The Hidden Wealth of Nations: The Scourge of Tax Havens, by Gabriel Zucman from 2015;
- The main financial media: New York Times,[62] Bloomberg News,[63] the Wall Street Journal,[64] Forbes,[65] the Financial Times,[66] The Economist,[67] the Washington Post,[68] and Fortune;[69]
- Some leading economists;[70][71][72][73][74]
- G20 economy, Brazil, who blacklisted Ireland in September 2016;[6][75] and potentially the U.S. State of Oregon whose State IRS recommended blacklisting Ireland in 2017.[76]
- The European Parliament in March 2019 voted to accept a report by 505 votes in favour to 63 against, recommending Ireland, as one several "EU tax havens", be included on the official EU Commission list of tax havens.[lower-alpha 14][78][79][80]
Ireland has also been labelled related terms to being a tax haven:
- In Germany, the related term tax dumping has been used against Ireland by German political leaders;[81][82]
- The Financial Stability Forum ("FSF") and the International Monetary Fund ("IMF") listed Ireland as an offshore financial centre in June 2000;[31][32][33][34]
- Bloomberg, in an article on PwC Ireland's managing partner Feargal O'Rourke, used the term tax avoidance hub;[83]
- The 2013 U.S Senate PSI Levin–McCain investigation into U.S. multinational tax activity, called Ireland the holy grail of tax avoidance;[84][85]
- As the OECD has never listed any of its 35 members as tax havens, Ireland, Luxembourg, the Netherlands and Switzerland are called OECD tax havens;[86]
- As the EU Commission has never formally listed any of its 28 members as tax havens, Ireland, Luxembourg, the Netherlands and Belgium are called EU tax havens.[87][88]
The term tax haven has been used by the Irish mainstream media and leading Irish commentators.[89][90][91][92][68][93] Irish elected TDs have asked the question: "Is Ireland a tax haven?".[94][95] A search of Dáil Éireann debates lists 871 references to the term.[96] Some established Irish political parties accuse the Irish State of tax haven activities.[97][98][99]
The international community at this point is concerned about the nature of tax havens, and Ireland in particular is viewed with a considerable amount of suspicion in the international community for doing what is considered – at the very least – on the boundaries of acceptable practices.
— Ashoka Mody, Ex-IMF mission chief to Ireland, "Former IMF official warns Ireland to prepare for end to tax regime", 21 June 2018.[100]
While Ireland has been considered a tax haven by many for decades, the global tax system that Ireland depends on to incentivize multinational corporations to move there is receiving an overhaul by a coalition of 130 nations. This would cause changes to Ireland's official corporate tax rate of 12.5%, and the associated rules sometimes described as helping companies based there avoid paying taxes to other countries where they make profits.[101] Originally Ireland was one of the few countries (one of nine) to oppose signing up for reform to a global minimum corporate tax rate of 15% and to force technology and retail companies to pay taxes based on where their goods and services were sold, rather than where the company was located. The Irish government would eventually agree to the terms of the deal after some debate. As of October 7, 2021 Ireland dropped its opposition to an overhaul of global corporate tax rules giving up its 12.5% tax rate.[102] The Irish Cabinet approved an increase from 12.5% to 15% in corporation tax for companies with turnover in excess of 750 million euros.[103] Additionally, the Irish Department of Finance has estimated that joining this global deal would reduce the country's tax take by 2 billion euros ($2.3 billion) a year, according to RTE. The other countries party to this deal did have to agree to compromise on a few key issues involved in the reform, dropping the “at least” in the statement “minimum corporate tax rate of at least 15%” updating it to just 15% — signaling that the rate would not be pushed up at a later date. Ireland was also given assurances that it could keep the lower rate for smaller firms located in the country.
Global U.S. BEPS hub
Ireland ranks in all non-political "tax haven lists" going back to the first lists in 1994,[lower-alpha 13][28] and features in all "proxy tests" for tax havens and "quantitative measures" of tax havens. The level of base erosion and profit shifting (BEPS) by U.S. multinationals in Ireland is so large,[8] that in 2017 the Central Bank of Ireland abandoned GDP/GNP as a statistic to replace it with Modified gross national income (GNI*).[105][106] Economists note that Ireland's distorted GDP is now distorting the EU's aggregate GDP,[107] and has artificially inflated the trade-deficit between the EU and the US.[108] (see Table 1).
Ireland's IP–based BEPS tools use "intellectual property" ("IP") to "shift profits" from higher-tax locations, with whom Ireland has bilateral tax treaties, back to Ireland.[lower-alpha 4] Once in Ireland, these tools reduce Irish corporate taxes by re-routing to say Bermuda with the Double Irish BEPS tool (e.g. as Google and Facebook did), or to Malta with the Single Malt BEPS tool (e.g. as Microsoft and Allergan did), or by writing-off internally created virtual assets against Irish corporate tax with the Capital Allowances for Intangible Assets ("CAIA") BEPS tool (e.g. as Apple did post 2015). These BEPS tools give an Irish corporate effective tax rate (ETR) of 0–2.5%. They are the world's largest BEPS tools, and exceed the aggregate flows of the Caribbean tax system.[8][9][43][109][110]
Ireland has received the most U.S. corporate tax inversions of any global jurisdiction, or tax haven, since the first U.S. tax inversion in 1983.[112]
While IP–based BEPS tools are the majority of Irish BEPS flows, they were developed from Ireland's traditional expertise in inter-group contract manufacturing, or transfer pricing–based (TP) BEPS tools (e.g. capital allowance schemes, inter-group cross-border charging), which still provide material employment in Ireland (e.g. from U.S. life sciences firms[113]).[111][114][115] Some corporates like Apple maintain expensive Irish contract manufacturing TP–based BEPS operations (versus cheaper options in Asia, like Apple's Foxconn), to give "substance" to their larger Irish IP–based BEPS tools.[116][117]
By refusing to implement the 2013 EU Accounting Directive (and invoking exemptions on reporting holding company structures until 2022), Ireland enables their TP and IP–based BEPS tools to structure as "unlimited liability companies" ("ULC") which do not have to file public accounts with the Irish CRO.[118][119]
Ireland's Debt–based BEPS tools (e.g. the Section 110 SPV), have made Ireland the 3rd largest global Shadow Banking OFC,[24][120] and have been used by Russian banks to circumvent sanctions.[121][122][123] Irish Section 110 SPVs offer "orphaning" to protect the identity of the owner, and to shield the owner from Irish tax (the Section 110 SPV is an Irish company). They were used by U.S. distressed debt funds to avoid billions in Irish taxes,[124][125][126] assisted by Irish tax-law firms using in-house Irish children's charities to complete the orphan structure,[127][128][129] that enabled the U.S. distressed debt funds to export the gains on their Irish assets, free of any Irish taxes or duties, to Luxembourg and the Caribbean (see Section 110 abuse).[130][131]
Unlike the TP and IP–based BEPS tools, Section 110 SPVs must file public accounts with the Irish CRO, which was how the above abuses were discovered in 2016–17. In February 2018 the Central Bank of Ireland upgraded the little-used L–QIAIF regime to give the same tax benefits as Section 110 SPVs but without having to file public accounts. In June 2018, the Central Bank reported that €55 billion of U.S.–owned distressed Irish assets, equivalent to 25% of Irish GNI*, moved out of Irish Section 110 SPVs and into L–QIAIFs.[132][133][134]
Green Jersey BEPS tool
Apple's Q1 2015 Irish restructure, post their €13 billion EU tax fine for 2004–2014, is one of the most advanced OECD-compliant BEPS tools in the world. It integrates Irish IP–based BEPS tools, and Jersey Debt–based BEPS tools, to materially amplify the tax sheltering effects, by a factor of circa 2.[136] Apple Ireland bought circa $300 billion of a "virtual" IP–asset from Apple Jersey in Q1 2015 (see leprechaun economics).[111][137] The Irish "capital allowances for intangible assets" ("CAIA") BEPS tool allows Apple Ireland to write-off this virtual IP–asset against future Irish corporation tax. The €26.220 billion jump in intangible capital allowances claimed in 2015,[138] showed Apple Ireland is writing-off this IP–asset over a 10-year period. In addition, Apple Jersey gave Apple Ireland the $300 billion "virtual" loan to buy this virtual IP–asset from Apple Jersey.[136] Thus, Apple Ireland can claim additional Irish corporation tax relief on this loan interest, which is circa $20 billion per annum (Apple Jersey pays no tax on the loan interest it receives from Apple Ireland). These tools, created entirely from virtual internal assets financed by virtual internal loans, give Apple circa €45 billion per annum in relief against Irish corporation tax.[137] In June 2018 it was shown that Microsoft is preparing to copy this Apple scheme,[139] known as "the Green Jersey".[136][137]
As the IP is a virtual internal asset, it can be replenished with each technology (or life sciences) product cycle (e.g. new virtual IP assets created offshore and then bought by the Irish subsidiary, with internal virtual loans, for higher prices). The Green Jersey thus gives a perpetual BEPS tool, like the double Irish, but at a much greater scale than the double Irish, as the full BEPS effect is capitalised on day one.
Experts expect the U.S. Tax Cuts and Jobs Act of 2017 ("TCJA") GILTI-regime to neutralise some Irish BEPS tools, including the single malt and the double Irish.[140] Because Irish intangible capital allowances are accepted as U.S. GILTI deductions,[141] the "Green Jersey" now enables U.S. multinationals to achieve net effective U.S. corporate tax rates of 0% to 2.5% via TCJA's participation relief.[17] As Microsoft's main Irish BEPS tools are the single malt and the double Irish, in June 2018, Microsoft was preparing a "Green Jersey" Irish BEPS scheme.[139] Irish experts, including Seamus Coffey, Chairman of the Irish Fiscal Advisory Council and author of the Irish State's 2017 Review of Ireland's Corporation Tax Code,[142][143] expects a boom in U.S. on-shoring of virtual internal IP assets to Ireland, via the Green Jersey BEPS tool (e.g. under the capital allowances for intangible assets scheme).[144]
Domestic tax tools
Ireland's Qualifying Investor Alternative Investment Fund ("QIAIF") regime is a range of five tax-free legal wrappers (ICAV, Investment Company, Unit Trust, Common Contractual Fund, Investment Limited Partnership).[145][146] Four of the five wrappers do not file public accounts with the Irish CRO, and therefore offer tax confidentiality and tax secrecy.[147][148] While they are regulated by the Central Bank of Ireland, like the Section 110 SPV, it has been shown many are effectively unregulated "brass plate" entities.[123][149][150][151][152] The Central Bank has no mandate to investigate tax avoidance or tax evasion, and under the 1942 Central Bank Secrecy Act, the Central Bank of Ireland cannot send the confidential information which QIAIFs must file with the Bank to the Irish Revenue.[153]
QIAIFs have been used in tax avoidance on Irish assets,[154][155][156][157] on circumventing international regulations,[158] on avoiding tax laws in the EU and the U.S.[159][160] QIAIFs can be combined with Irish corporate BEPS tools (e.g. the Orphaned Super–QIF), to create routes out of the Irish corporate tax system to Luxembourg,[10] the main Sink OFC for Ireland.[161][162][163] It is asserted that a material amount of assets in Irish QIAIFs, and the ICAV wrapper in particular, are Irish assets being shielded from Irish taxation.[164][165] Offshore magic circle law firms (e.g. Walkers and Maples and Calder, who have set up offices in Ireland), market the Irish ICAV as a superior wrapper to the Cayman SPC (Maples and Calder claim to be a major architect of the ICAV),[166][167][168] and there are explicit QIAIF rules to help with re-domiciling of Cayman/BVI funds into Irish ICAVs.[169]
Captured state
There is evidence Ireland meets the captured state criteria for tax havens.[11][12][150][171] When the EU investigated Apple in Ireland in 2016 they found private tax rulings from the Irish Revenue giving Apple a tax rate of 0.005% on over EUR€110 billion of cumulative Irish profits from 2004 to 2014.[172][173][174]
When the Irish Finance Minister Michael Noonan was alerted by an Irish MEP in 2016 to a new Irish BEPS tool to replace the Double Irish (called the Single Malt), he was told to "put on the green jersey".[1] When Apple executed the largest BEPS transaction in history in Q1 2015, the Central Statistics Office suppressed data to hide Apple's identity.[175][176]
Noonan changed the capital allowances for intangible assets scheme rules, the IP–based BEPS tool Apple used in Q1 2015, to reduce Apple's effective tax rate from 2.5% to 0%.[177] When it was discovered in 2016 that U.S. distressed debt funds abused Section 110 SPVs to shield €80 billion in Irish loan balances from Irish taxes, the Irish State did not investigate or prosecute (see Section 110 abuse). In February 2018, the Central Bank of Ireland, which regulates Section 110 SPVs, upgraded the little used tax-free L-QIAIF regime, which has stronger privacy from public scrutiny.[133][178] In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (or 25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs.[132][133]
The June 2017 OECD Anti-BEPS MLI was signed by 70 jurisdictions.[179] The corporate tax havens, including Ireland, opted out of the key Article 12.[180]
Global legal firm Baker McKenzie,[181] representing a coalition of 24 multinational U.S. software firms, including Microsoft, lobbied Michael Noonan, as [Irish] minister for finance, to resist the [OECD MLI] proposals in January 2017. In a letter to him the group recommended Ireland not adopt article 12, as the changes "will have effects lasting decades" and could "hamper global investment and growth due to uncertainty around taxation". The letter said that "keeping the current standard will make Ireland a more attractive location for a regional headquarters by reducing the level of uncertainty in the tax relationship with Ireland's trading partners".
Tax haven investigator Nicholas Shaxson documented how Ireland's captured state uses a complex and "siloed" network of Irish privacy and data protection laws to navigate around the fact that its tax tools are OECD–whitelisted,[182][183] and therefore must be transparent to some State entity.[11] For example, Irish tax-free QIAIFs (and L–QIAIFs) are regulated by the Central Bank of Ireland and must provide the Bank with details of their financials. However, the 1942 Central Bank Secrecy Act prevents the Central Bank from sending this data to the Revenue Commissioners.[153] Similarly, the Central Statistics Office (Ireland) stated it had to restrict its public data release in 2016–17 to protect the Apple's identity during its 2015 BEPS action, because the 1993 Central Statistics Act prohibits use of economic data for revealing such activities.[184] When the EU Commission fined Apple €13 billion for illegal State aid in 2016, there were no official records of any discussion of the tax deal given to Apple outside of the Irish Revenue Commissioners as such data is also protected.[185]
When Tim Cook stated in 2016 that Apple was the largest tax-payer in Ireland, the Irish Revenue Commissioners quoted Section 815A of the 1997 Tax Acts that prevents them disclosing such information, even to members of Dáil Éireann, or the Irish Department of Finance (despite the fact that Apple is circa one-fifth of Ireland's GDP).[186]
Commentators note the plausible deniability provided by Irish privacy and data protection laws, that enable the State to function as a tax haven while maintaining OECD compliance. They ensure the State entity regulating each tax tool are "siloed" from the Irish Revenue, and public scrutiny via FOI laws.[11][187][188]
In February 2019, The Guardian reported on leaked Facebook internal reports revealing the influence Facebook had on the Irish State, to which Cambridge University academic John Naughton stated: "the leak was “explosive” in the way it revealed the “vassalage” of the Irish state to the big tech companies".[189] In April 2019, Politico reported on concerns that Ireland was protecting Facebook and Google from the new EU GDPR regulations, stating: "Despite its vows to beef up its threadbare regulatory apparatus, Ireland has a long history of catering to the very companies it is supposed to oversee, having wooed top Silicon Valley firms to the Emerald Isle with promises of low taxes, open access to top officials, and help securing funds to build glittering new headquarters."[190]
US multinational companies in Ireland
American multinationals play a substantial role in Ireland's economy, attracted by Ireland's BEPS tools, that shield their non–US profits from the historical US "worldwide" corporate tax system. In contrast, multinationals from countries with "territorial" tax systems, by far the most common corporate tax system in the world, do not need to use corporate–tax havens such as Ireland, as their foreign income is taxed at much lower rates.[192]
For example, in 2016–17, US–controlled multinationals in Ireland:
- Directly employed one–quarter of the Irish private sector workforce;[193]
- Created "higher-value" jobs at an average wage of €85k (€17.9 billion wage roll for 210,443 staff) vs. Irish domestic industrial wage of €35k;[194]
- Paid €28.3 billion in 2016 in taxes (€5.5 billion), wages (€17.9 billion on 210,443 staff) and capital spending (€4.9 billion);[195][194]
- Paid 80 per cent of Irish corporation and business taxes, which totalled just over €8 billion;[196]
- Paid circa 50 per cent of Irish salary taxes (due to higher paying jobs), 50 per cent of Irish VAT, and 92 per cent of Irish customs and excise duties;
(this was claimed by a leading Irish tax expert (and Past President of the Irish Tax Institute), but is not fully verifiable)[197] - Created 57 per cent of private sector non-farm value-add (40% of value-add in Irish services and 80% of value-add in Irish manufacturing);[193][198]
- Made up 25 of the top 50 Irish companies, by 2017 turnover (see Table 2, below); the only non–U.S/non–Irish other companies are UK companies which either sell into Ireland, like Tesco, or date from pre–2009, when the UK reformed its corporate tax system to a "territorial" regime.[20]
- American–Ireland Chamber of Commerce estimated the value of US investment in Ireland in 2018 was €334 billion, exceeding Irish GDP (€291 billion in 2016).[199]
Rank (By Revenue) |
Company Name[20] |
Operational Base[200] |
Sector (if non–IRL)[20] |
Inversion (if non–IRL)[112] |
Revenue (€2017 bn)[20] |
---|---|---|---|---|---|
1 | Apple Ireland | United States | technology | not inversion | 119.2 |
2 | CRH plc | Ireland | – | – | 27.6 |
3 | Medtronic plc | United States | life sciences | 2015 inversion | 26.6 |
4 | United States | technology | not inversion | 26.3 | |
5 | Microsoft | United States | technology | not inversion | 18.5 |
6 | Eaton | United States | industrial | 2012 inversion | 16.5 |
7 | DCC plc | Ireland | – | – | 13.9 |
8 | Allergan Inc | United States | life sciences | 2013 inversion | 12.9 |
9 | United States | technology | not inversion | 12.6 | |
10 | Shire | United Kingdom | life sciences | 2008 inversion | 12.4 |
11 | Ingersoll-Rand | United States | industrial | 2009 inversion | 11.5 |
12 | Dell Ireland | United States | technology | not inversion | 10.3 |
13 | Oracle | United States | technology | not inversion | 8.8 |
14 | Smurfit Kappa Group | Ireland | – | – | 8.6 |
15 | Ardagh Glass | Ireland | – | – | 7.6 |
16 | Pfizer | United States | life sciences | not inversion | 7.5 |
17 | Ryanair | Ireland | – | – | 6.6 |
18 | Kerry Group | Ireland | – | – | 6.4 |
19 | Merck & Co | United States | life sciences | not inversion | 6.1 |
20 | Sandisk | United States | technology | not inversion | 5.6 |
21 | Boston Scientific | United States | life sciences | not inversion | 5.0 |
22 | Penneys Ireland | Ireland | – | – | 4.4 |
23 | Total Produce | Ireland | – | – | 4.3 |
24 | Perrigo | United States | life sciences | 2013 inversion | 4.1 |
25 | Experian | United Kingdom | technology | 2006 inversion | 3.9 |
26 | Musgrave Group | Ireland | – | – | 3.7 |
27 | Kingspan Group | Ireland | – | – | 3.7 |
28 | Dunnes Stores | Ireland | – | – | 3.6 |
29 | Mallinckrodt Pharma | United States | life sciences | 2013 inversion | 3.3 |
30 | ESB Group | Ireland | – | – | 3.2 |
31 | Alexion Pharma | United States | life sciences | not inversion | 3.2 |
32 | Grafton Group | Ireland | – | – | 3.1 |
33 | VMware | United States | technology | not inversion | 2.9 |
34 | Abbott Laboratories | United States | life sciences | not inversion | 2.9 |
35 | ABP Food Group | Ireland | – | – | 2.8 |
36 | Kingston Technology | United States | technology | not inversion | 2.7 |
37 | Greencore | Ireland | – | – | 2.6 |
38 | Circle K Ireland | Ireland | – | – | 2.6 |
39 | Tesco Ireland | United Kingdom | food retail | not inversion | 2.6 |
40 | McKesson | United States | life sciences | not inversion | 2.6 |
41 | Peninsula Petroleum | Ireland | – | – | 2.5 |
42 | Glanbia plc | Ireland | – | – | 2.4 |
43 | Intel Ireland | United States | technology | not inversion | 2.3 |
44 | Gilead Sciences | United States | life sciences | not inversion | 2.3 |
45 | Adobe | United States | technology | not inversion | 2.1 |
46 | CMC Limited | Ireland | – | – | 2.1 |
47 | Ornua Dairy | Ireland | – | – | 2.1 |
48 | Baxter | United States | life sciences | not inversion | 2.0 |
49 | Paddy Power | Ireland | – | – | 2.0 |
50 | ICON Plc | Ireland | – | – | 1.9 |
Total | 454.4 |
From the above table:
- US–controlled firms are 25 of the top 50 and represent €317.8 billion of the €454.4 billion in total 2017 revenue (or 70%);
- Apple alone is over 26% of the total top 50 revenue and greater than all top 50 Irish companies combined (see leprechaun economics on Apple as one-fifth of Irish GDP);
- UK–controlled firms are 3 of the top 50 and represent €18.9 billion of the €454.4 billion in total 2017 revenue (or 4%); Shire and Experian are pre the UK transformation to a "territorial" model;
- Irish–controlled firms are 22 of the top 50 and represent €117.7 billion of the €454.4 billion in total 2017 revenue (or 26%);
- There are no other firms in the top 50 Irish companies from other jurisdictions.