[gamblor956]

The double-Irish is definitely a loophole. The basic premise of the loophole is that Irish-incorporated companies don't owe Irish income taxes on their business activities if they are not managed in Ireland.

This is a relatively recent change to the Irish tax code (based on the pace of tax law development)--and was introduced only after the development of transfer pricing rules (assignment of income to/between subsidiaries of multinational companies). In other words--the loophole was deliberately designed to get around U.S. and European transfer pricing rules and make Ireland "competitive" for multinational corporations.