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Investor Presentaiton

Corporation Tax • Originally low corporation tax attracted FDI employment to Ireland • Non-US firms not permitted to exploit opportunity by domestic tax authorities . Bulk of corporation tax is paid by small number of US firms. Exceptional profit margins because location of IP in Ireland. • • In individual companies, such as Apple, IP held by separate subsidiary from company employing large numbers in Ireland • • Employment decision separable from where IP is held and tax paid (or not paid) . Trump tax reform may have benefited Ireland because GILTI rate 10.5% • Very vulnerable to changes in US tax law - e.g. proposed Biden reforms? • OECD process would have impact. Department of Finance estimate up to €2bn • With US tax reforms total of €6bn could be at risk: c. 3% of GNI*, but direct employment impact likely to be low
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