12 Facts About Double Irish

Double Irish arrangement was a base erosion and profit shifting corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.

Double Irish enables the IP to be charged-out from Ireland, which has a large global network of full bilateral tax treaties.

The Double Irish enables the hypothetical $95, which was sent from Germany to Ireland, to be sent on to a tax haven such as Bermuda without incurring any Irish taxation.

However, if IRL1 sends the money to a new Dutch company DUT1, via another royalty payment scheme, no Double Irish withholding tax is payable as Ireland does not levy withholding tax on transfers within EU states.

The Irish Revenue issued private rulings to Apple in 1991 and 2007 regarding this hybrid-double Irish structure, which the EU Commission considered as illegal State aid.

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The Double Irish media picked up the article, but when an Double Irish MEP notified the then Finance Minister, Michael Noonan, he was told to "put on the green jersey".

In November 2018, the Double Irish Government amended the Ireland–Malta tax treaty to prevent the Single Malt BEPS tool being used between Ireland and Malta ; however, the exact closure date of the Double Irish Single Malt BEPS tool with Malta was deferred until September 2019.

In September 2021, The Double Irish Times reported that US pharmaceutical firm Abbott Laboratories was still using the Single Malt tool to shield profits on its COVID-19 testing kits.

Example, in Q1 2015, Apple used the CAIA tool when its Double Irish subsidiary purchased US$300 billion in intangible assets from an Apple subsidiary based in Jersey.

In September 2009, the commission recommended that the Double Irish State provide capital allowances for the acquisition of intangible assets, creating the CAIA BEPS tool.

In January 2020, The Double Irish Times speculated that Google Inc, was considering using the CAIA BEPS tool.

The Double Irish State refutes tax haven labels as unfair criticism of its low, but legitimate, 12.