These sweetheart taxation deals should stop in Ireland and other tax havens. It benefits none; although on paper it looks that Ireland is doing too well, the reality is not that rosy for its residents.
Apple employees a ton of people in Ireland same as pretty much all top tier tech companies. Outside of crazy real estate prices Ireland is actually doing pretty well.
Employing lots of foreigners who pay insane rent prices and are taxed heavily doesn't really benefit anyone else other than home owners who already were fleecing people due to the lack of construction.
Ireland is doing well as a country in GDP terms (ignoring debt) but the people in the mid and lower tiers don't necessarily do well at all.
It's increasingly classist and it has bad and inefficient healthcare, lack of police, excessive bureocracy and lack of political change due to an entrenched political class.
Ireland, it's only doing well for some and only in the surface. Corrupt to an unbelievable degree if you actually see it up close, and not through layers of numbers and "process".
> Ireland is doing well as a country in GDP terms (ignoring debt) but the people in the mid and lower tiers don't necessarily do well at all.
Compared to what? Certainly not the Ireland of 25 years ago.
> It's increasingly classist and it has bad and inefficient healthcare, lack of police, excessive bureocracy and lack of political change due to an entrenched political class.
The only country in the EU where wealth inequality is decreasing, which has a struggling healthcare system but world-class outcomes, once of the least bureaucratic countries in the world, and which has a stable democracy which is about to undergo a completely peaceful transfer of power when Sinn Féin comes into power following the next election.
I can only say that if you believe what you've written about Ireland, you simply don't have the perspective to comment on this.
Compared to today. Compared to 5 years ago. Compared to 15 years ago.
Citation needed and the "peaceful transition" is laughable as a selling point. Is the bar so low? Lol.
It'll be grand land has yet another defender that wants people to not rock the boat and attacks anyone who showcases how backwards thing are. Talk to a real person and not one who has their life easily laid out...
Perspective, huh? Shame on your disingenuous response.
> Compared to today. Compared to 5 years ago. Compared to 15 years ago.
So your contention is that Ireland hasn't improved since 2018 or 2003? For almost everyone in almost every category, that is not true.
> Citation needed and the "peaceful transition" is laughable as a selling point. Is the bar so low? Lol.
No, the bar is very high as Ireland is one of the top tier countries in the world to live by almost any measure. That was a direct response to your claim of a "lack of political change due to an entrenched political class", which is patently untrue in Ireland.
> It'll be grand land has yet another defender that wants people to not rock the boat and attacks anyone who showcases how backwards thing are.
Ireland is certainly not perfect. I work in the medical field and am constantly frustrated at the medical and social services. However, I've also worked around the world and know that while Ireland is in fact an outlier, it's a positive outlier compared to even the developed world.
> Talk to a real person and not one who has their life easily laid out...
I do, daily, and not only online. The kind of disingenuous negativity you hold is not common.
> Perspective, huh? Shame on your disingenuous response.
The irony is palpable. Luckily those of us working to improve the country aren't discouraged by those on the sidelines offering only empty critiques.
> No, the bar is very high as Ireland is one of the top tier countries in the world to live by almost any measure
Like healthcare? Lol. What a disingenuous piece of manure.
> "lack of political change due to an entrenched political class", which is patently untrue in Ireland
You just claim it's untrue but offer no actual arguments. Your rabid offended defense of the country speaks volumes.
> work in the medical field and am constantly frustrated at the medical and social services.
DING DING DING. there it is. That's why you're offended. You're a crook who is part of the problem and has no perspective.
> However, I've also worked around the world and know that while Ireland is in fact an outlier, it's a positive outlier compared to even the developed world.
I like how you don't even say where.
> he irony is palpable. Luckily those of us working to improve the country aren't discouraged by those on the sidelines offering only empty critiques
My critiques weren't empty. They were poignant and your defenses were "no, lie". Kid level stuff and clearly very entrenched in maintain your current thing going.
You're part of the problem. I'm not surprised you'd defend it as such. It's very easy for people who benefit from the corruption and bureocracy to want to keep it going. Healthcare in Ireland is one of the biggest and worst scams in the country and the only way to paint in a good light is to compare it to the US, which is the go to tactic.
Shame on you for being willfully blind to the realities of people not well off because you're in on it.
I'm pretty sure. They're poking fun at people who see the billions in tax dodge BEPS schemes included in Ireland GDP and think it has any bearing in reality.
This is just... nonsense. You need to get around a bit more if you don't think the quality of life in Ireland is high in comparison to most places in the world.
The reality in Ireland is still that Ireland is a wealthy, stable, safe, educated liberal democracy, which is not at all what it was when I was young. Although suffering from the same housing-, cost-of-living-, refugee-, and public-service-crises as most other Western nations, its path has been extremely successful and beneficial to its citizens.
I think you might just be too young and too insulated to see how successful the policies have been.
Well, they are not sustainable, but Ireland no longer relies on them, so it's a moot point. The policies enabled the rapid development over a 25 year period and as the country became richer and the progress became self-sustaining, the arrangements were discontinued.
For example, the "Double Irish" arrangement, which is the subject of this case, was only in use up to 2014 (and was modelled on and often paired with the "Dutch Sandwich" BEPS arrangement, so you should note that Ireland wasn't the only EU country playing these games). It was this case that closed the Double Irish arrangement and while "Green Jersey"/CAIA partially took it's place, the legitimate tax take was already more than sustainable.
Now that Ireland has agreed to a global minimum corporate tax (CT) rate, it's likely that the CT take in Ireland will fall over time, but the inflated CT take of recent years has been treated as a windfall and not current income.
> If Ireland has closed all the loopholes then why do the phantom exports (US subsidiary buying IPs) account for 38% of total exports of this year?
I didn't say they have closed all the loopholes (nor have other EU countries). What I said was that Ireland is no longer reliant on them, in that the country does not fund current expenditure from the CT take. They are openly viewed as windfalls.
> Provided that they dont find another loophole.
It may happen, but one thing's for sure, Ireland won't be alone.
>Well, they are not sustainable, but Ireland no longer relies on them, so it's a moot point.
Not true. Foreign companies are 80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add.
>For example, the "Double Irish" arrangement, which is the subject of this case, was only in use up to 2014 (and was modelled on and often paired with the "Dutch Sandwich" BEPS arrangement, so you should note that Ireland wasn't the only EU country playing these games).
The Double Irish was immediately replaced by the Single Malt and the Irish tax regime has started to add more traditional tools to tax evasion (e.g. QIAIF, L–QIAIF, and ICAV).
> Not true. Foreign companies are 80% of Irish corporation tax, 25% of Irish labour, 25 of top 50 Irish firms, and 57% of Irish value-add.
This isn't a rebuttal. Ireland is absolutely dependent on foreign firms, but no longer dependent on the inflated CT take from BEPS schemes. The majority of the above is now genuine work undertaken in Ireland, not IP tax avoidance schemes.
> The Double Irish was immediately replaced by the Single Malt and the Irish tax regime has started to add more traditional tools to tax evasion (e.g. QIAIF, L–QIAIF, and ICAV).
Yes, agreed (although Ireland is not alone in this, even in the EU). However, that doesn't change the fact that Ireland is no dependent on this tax income.
Given your apparent knowledge of the schemes involved, this should be clear to you?
> It could be argued it's just plain old corruption.
How so? That's certainly a novel take that hasn't been raised by any parties to the case including the plaintiffs, so I'd like to hear your reasoning here.
> Also, it's unclear to me the things you are listing followed due to aforementioned corruption.
As a side-note, Ireland is one of the least corrupt countries in the world and broadly comparable to, say, Sweden (https://www.transparency.org/en/countries/ireland), so it's not a case that the country is a beneficiary of corrupt practices. It does, however, operate in its own interest.
Honestly, I think you don't understand the issues at hand here well enough to make this accusation. Are you aware of the political environment at the time? Of the path into law of the Lisbon Treaty? Do you know what the Irish Guarantees are, and why at the time this deal was uncontroversial in Ireland?
If anything, this is the opposite of corruption. It's likely that if the general public in Ireland knew of this outcome in 2009, the second Lisbon Treaty referendum wouldn't have passed and TFEU would have stalled completely. Short memories abound here.
Ok, then SAP will have to pay taxes on worldwide income to both the USA and Germany, or will international companies be allowed to headquarter in a country with the best worldwide tax policy? Will Chinese companies have an advantage over Americans ones because they are just taxed in the jurisdiction they are doing business in vs. being taxed on world income by China?
That’s exactly how it should be. Without nation to nation competition, taxes would be even more outrageous than they already are. The institution that monopolizes violence in order to tax should be at the very least threatened by the risk of losing its constituents to other nations/regions that offer a better deal.
Global corporations aren't generally looking for the lowest tax rates to house their companies, they are looking for the ways to avoid paying taxes in a higher tax country by offsetting them in tax havens. They do this by splitting themselves into multiple shell companies, then play dodgy games of selling things to themselves at stupid prices: charge one subsidiary a few dollars for a missile and another $50k for a roll of toilet paper. This practice should be illegal as it's basically tax evasion and fraud. But, our politicians are corrupt cowards, so we all have to pretend it's just good housekeeping and lump it.
All the megacorps would be fantastically successful without playing these stupid games (most of them did their greatest growth spurts before they started doing it), and our countries would be so much nicer places to live if we only agreed that paying back to the society that nurtured you was an important part of the social contract.
Tax is civilisation. By pushing back against it like this you are essentially pushing back against civilisation, and the effects of this are all around us in our crumbling infrastructure, failing health, and desperate tent cities.
> . They do this by splitting themselves into multiple shell companies, then play dodgy games of selling things to themselves at stupid prices: charge one subsidiary a few dollars for a missile and another $50k for a roll of toilet paper.
I was under the impression that the vast majority of it was via collecting "royalties" for the branding? Ie: a company's trademarked brands are owned by a holding company HQ'd in a tax shelter, and the parent company pays a licensing fee that just so happens to equal most if not all of their profits for the year.
It seems like it'd be pretty trivial to target via a tax on payments for intellectual property royalties to offshore corporations or a law that deems it tax evasion to pay IP royalties to a holding company outside the US for a corporation that is primarily operating in the US and Canada.
Suppose one government at time x makes corrupt/stupid decisions costing taxpayers at time x+30 years by having to pay debts that serve no benefit. I don’t see why I should be responsible to pay that, and it has been a factor in deciding which US jurisdiction to live in.
> and our countries would be so much nicer places to live if we only agreed that paying back to the society that nurtured you was an important part of the social contract.
This is constantly in flux, and declining fertility rates kind of throw this calculation for a loop.
When you manipulate the playing field to give you an advantage, it's not a competition. The idea that companies or whole nations "compete" by lowering wages/taxes, will destroy capitalism. We can already observe the bad effect: The company sector has become a net saver in most western countries, while tax-cut proponents claim, companies will invest more with lower taxes. It's a lie. The role of the company sector is to make debt and invest. If that's not the case anymore, someone else has to make the debt instead. Which is the government. How is that still capitalism?
You missed the memonof a global minimum corporate tax, thatbia being implemented rihht now, didn't you?
It seems the majoroty of people, and governments, have not too much interest to exist in a world of unlimited capitalism only benefiting the largest corporations and richest of people.
I upvoted you because you are right. I will never understand the excitement of the Hacker News community to pay a 50% penalty to the worst type of people on earth, those that do not produce.
It's the same excitement that I feel when I visit a relative in hospital and see they're taken care of without going bankrupt, when I take my kids to schools that my taxes paid for, on roads that my taxes paid for, in a country that isn't 10 meters under water because of the taxes that I paid in a place where poverty is reasonably rare (though not yet completely eradicated) and where because of that it is pretty safe to live and so on.
And what have those Romans ever done for us anyway?
What, you wouldn't like a world where you can only drive on the roads you pay for, as part of your AppleWay™ subscription? Not to be confused with the roads available on GoogleMotor™, of course! But there would be some interoperability: every pedestrian crossing would support the Microsoft Nickel&Dime™ system, so you can pay to enable the crossing. No more would we be slaves of those irresponsible elected bureaucrats, but rather conscious consumers making informed choices between different companies!
You don't have a safety net. You have interest payments on the Iraq War, Gulf War, Afghanistan War, GFC bailouts, HN bank bailout (SVC), and mountains and mountains of past spending. It will be 100% of the budget in not too long.
It's a problem like the prisoner dilemma. It's beneficial to the country that "deflects" and gives a discount, but makes everyone worse off than if all countries held line on a higher tax rate.
(disclaimer: I mean it from a direct perspective of maximizing tax income. In this comment I'm not getting into the deeper economics/politics/philosophy of whether higher or lower taxes are better overall).