Will Ireland's corporation tax survive?


#445

Depends what they’re doing; the speed of light mounts up quite quickly for some applications, but more importantly the switching delays can be significant since you don’t necessarily have a single unbroken strand of glass from your datacenter to the Norwegian datacenter.

Also datacenter do have more than one input; the connectivity is a crucial component, and Dublin does quite well for that, amazingly.


#446

This news story has implications for Ireland. More income will be taxed in UK rather than in Ireland.
irishtimes.com/business/econ … -1.2508797
130m may be petty cash to Google but not to Ireland.


#447

Still, if a Norwegian soverign wealth fund wanted to build a post-oil economy then this somewhere where they could afford to invest in IT infrastructure and then leverage their competitive advantage of excess hydro-electric capacity and cool climate.


#448

Lots of Nordic countries are trying that (e.g. Iceland). The problem is that you need the exact right magic mix of cheap power, multi-route connectivity, cheap real estate, and tax breaks. Amazingly, Ireland seems to have stumbled on a good combination, probably completely by accident. There’s also a decent industry-funded lobby group (Host In Ireland) that markets Ireland abroad as a datacenter and hosting location.

A big drawback is having multiple fibre landings in order to give true diversity. Ireland has that by accident of geography, so we’re ahead of lots of other countries.


#449

Don’t foget weather. The cheapest form of air conditioning is not having to do any. And no heating either. With a year round temperature in the low teens ( :cry: ) we’re well placed even compared to our nearest neighbour with their extremes of mild sunshine and some frost.


#450

That is tragically funny. I recall Dylan Moran’s comment the weather in Ireland is “Fierce Mild”


#451

wsj.com/articles/johnson-controls-tyco-to-merge-in-inversion-deal-1453724828

Tyco Johnson Controls merger/inversion. 8DD

EDIT TO include Hillary’s reaction


#452

irishtimes.com/news/world/eu … -1.2512772
*
“Today’s announcement in Brussels is the latest attempt at a EU-wide approach to the practice of corporate tax planning. The initiative is expected to include proposals to ban companies from shifting profits to subsidiaries in low- tax nations, as well as a proposal to curb the practice of companies using debt interest payments to lower tax bills.
The package will not include details of the revised CCCTB, which is instead expected to be launched in the autumn. What will be significant for Ireland is whether any of the measures go beyond the standards of the OECD rules agreed last year”*


#453

There are a large number of mechanisms that large corporations use to avoid tax that seem to be unjustifiable:

  • borrowing to issue dividends so they don’t have to bring money in to their HQ country from the tax haven.
  • claiming the interest from borrowing to issue dividends as an expense.
  • intra-company IP/licensing. So Motorola pays Apple a licence fee for use of a patent. Fair enough, that’s a cost to Motorola and a gain to Apple. Then Apple Ireland turns that gain into a cost and whips it off to Holland and thence to some tax haven. I don’t believe that IP payments to related companies should be permitted.
  • being stateless. In my view, if you’re stateless, you don’t own anything.
  • using the laws of one country despite not being resident there. So patent wars in the US despite not being HQ’d in the US.
  • averaging out debt and profit (taking on debt to pay costs so the interest counts against profit).
  • agreed tax bills - taxation authorities need to grow a pair and start doing their job.

So what gives? Why is this permitted?


#454

The problem is that a lot of those rules actually make sense on their own, on a small scale. They can and are abused though. Take this one:

But then how do I obtain a worldwide patent on my widget? I can’t be HQed in every country in the world, but I would like to sell it globally, or at least have global patent protection against copy-cats. There is a legitimate reason to allow global IP rights.


#455

How can we (Ireland) be forced to adopt their new corporate tax rules when we have an opt out under Lisbon treaty II?


#456

Ireland signs up to tackle tax avoidance by multinationals with 30 other OECD countries

independent.ie/business/worl … 03966.html


#457

Right, but there has to be a better mechanism. Perhaps a central patent resolution mechanism? I know it’s pipe-dreamy, but that’s one of the things government is for. They should all get off their pot filling holes and do some work.


#458

If the politicians got up off their holes and stopped all this where would they make all their money after they retired. Topaz can’t run without the Biff. Middle Eastern peace can’t be obtained if Tony doesn’t have a big office, how can Wall St. make money without the consulting of Greenspan associates…


#459

Apple may owe Ireland $19 billion, but Ireland doesn’t want the money. Here’s why - Washington Post

Depending on the outcome of an official investigation, Apple may face a bill that is estimated at between $8 billion and $19 billion for underpaid taxes to the Irish government. The Irish government really, really doesn’t want to get this money and is fighting as hard as it can to avoid receiving it. That may sound weird to ordinary people, who assume that governments want to squeeze individuals and businesses for as much taxes as they can get. But if you understand the politics of international corporation tax, it all makes sense.


#460

EU announces corporate tax anti-avoidance package - -> out-law.com/en/articles/2016 … -package-/


#461

Wow, excellent; that sounds way stricter than I hoped, particuarly the GAAR. It already exists for individuals, so why companies have been able to get away with it for so long, well, I guess we all know the answer to that one :frowning:


#462

America will be calling soon for their taxes back.

Taxes will be paid but on a deferred date.

And I couldn’t agree more…

forbes.com/sites/timworstall … 72c31a79e3


#463

Just 10 firms paid 50% of record Irish corporation tax in 2015

finfacts.ie/Irish_finance_ne … n-2015-514


#464

SBP reports that Italian authorities have opened a criminal investigation into 5 executives in Google Ireland for illegally shifting sales out of Italy and into Ireland.