IDEAS home Printed from https://ideas.repec.org/a/eso/journl/v50y2019i2p325-340.html
   My bibliography  Save this article

Aggressive Tax Planning Practices and Inward-FDI Implications for Ireland of the New US Corporate Tax Regime

Author

Listed:
  • Frank Barry

    (Trinity College Dublin)

Abstract

National corporate tax systems interact with each other in complex ways. Interactions with the US tax system are particularly important for Ireland given the significance of the US MNC presence in the Irish economy. The US system changed dramatically with the passage of the Trump administration’s Tax Cuts and Jobs Act. This paper outlines the history of corporate tax policy in the two jurisdictions and how the systems interacted up to the time of the recent changes. It also details the type of aggressive tax planning practices that grew up around the location of intellectual property assets. The likely implications of the new US tax regime for intellectual property location and inward FDI in Ireland are then assessed.

Suggested Citation

  • Frank Barry, 2019. "Aggressive Tax Planning Practices and Inward-FDI Implications for Ireland of the New US Corporate Tax Regime," The Economic and Social Review, Economic and Social Studies, vol. 50(2), pages 325-340.
    • Handle: RePEc:eso:journl:v:50:y:2019:i:2:p:325-340
    as

    Download full text from publisher

    File URL: https://www.esr.ie/article/view/1184/225
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Desai, Mihir A. & Foley, C. Fritz & Hines, James Jr., 2006. "The demand for tax haven operations," Journal of Public Economics, Elsevier, vol. 90(3), pages 513-531, February.
    2. Altshuler, Rosanne & Fulghieri, Paolo, 1994. "Incentive Effects of Foreign Tax Credits on Multinational Corporations," National Tax Journal, National Tax Association;National Tax Journal, vol. 47(2), pages 349-361, June.
    3. Marshall Reinsdorf & Matthew J. Slaughter, 2009. "International Trade in Services and Intangibles in the Era of Globalization," NBER Books, National Bureau of Economic Research, Inc, number rein09-1, May.
    4. John Mutti & Harry Grubert, 2009. "The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad," NBER Chapters, in: International Trade in Services and Intangibles in the Era of Globalization, pages 111-137, National Bureau of Economic Research, Inc.
    5. Rosanne Altshuler & Harry Grubert, 2005. "The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies," CESifo Working Paper Series 1613, CESifo.
    6. Mr. Nigel A Chalk & Mr. Michael Keen & Ms. Victoria J Perry, 2018. "The Tax Cuts and Jobs Act: An Appraisal," IMF Working Papers 2018/185, International Monetary Fund.
    7. Daragh Clancy, 2019. "US corporate tax rate cuts: Spillovers to the Irish economy," Working Papers 38, European Stability Mechanism.
    8. Altshuler, Rosanne & Fulghieri, Paolo, 1994. "Incentive Effects of Foreign Tax Credits on Multinational Corporations," National Tax Journal, National Tax Association, vol. 47(2), pages 349-61, June.
    9. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2014. "Ownership of intellectual property and corporate taxation," Journal of Public Economics, Elsevier, vol. 112(C), pages 12-23.
    10. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 109(1), pages 149-182.
    11. Frank Barry & Adele Bergin, 2012. "Inward Investment and Irish Exports over the Recession and Beyond," The World Economy, Wiley Blackwell, vol. 35(10), pages 1291-1304, October.
    12. Spengel, Christoph & Heinemann, Friedrich & Olbert, Marcel & Pfeiffer, Olena & Schwab, Thomas & Stutzenberger, Kathrin, 2018. "Analysis of US corporate tax reform proposals and their effects for Europe and Germany. Final report: Update 2018," ZEW Expertises, ZEW - Leibniz Centre for European Economic Research, number 181905, September.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. John FitzGerald, 2020. "National Accounts for a Global Economy: The Case of Ireland," NBER Chapters, in: Challenges of Globalization in the Measurement of National Accounts, pages 65-101, National Bureau of Economic Research, Inc.
    2. Barry Frank, 2019. "Ireland and the changing global foreign direct investment landscape," Administration, Sciendo, vol. 67(3), pages 93-110, August.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. James Nebus, 2019. "Will tax reforms alone solve the tax avoidance and tax haven problems?," Journal of International Business Policy, Palgrave Macmillan, vol. 2(3), pages 258-271, September.
    2. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2014. "Ownership of intellectual property and corporate taxation," Journal of Public Economics, Elsevier, vol. 112(C), pages 12-23.
    3. Frank Barry & Adele Bergin, 2019. "Export Structure, FDI and the Rapidity of Ireland’s Recovery from Crisis," The Economic and Social Review, Economic and Social Studies, vol. 50(4), pages 707-724.
    4. Fuest, Clemens & Hugger, Felix & Neumeier, Florian, 2022. "Corporate profit shifting and the role of tax havens: Evidence from German country-by-country reporting data," Journal of Economic Behavior & Organization, Elsevier, vol. 194(C), pages 454-477.
    5. Jones, Chris & Temouri, Yama, 2016. "The determinants of tax haven FDI," Journal of World Business, Elsevier, vol. 51(2), pages 237-250.
    6. James R. Hines, Jr., 1997. "Taxed Avoidance: American Participation in Unsanctioned International Boycotts," NBER Working Papers 6116, National Bureau of Economic Research, Inc.
    7. Lisa De Simone & Lillian F. Mills & Bridget Stomberg, 2019. "Using IRS data to identify income shifting to foreign affiliates," Review of Accounting Studies, Springer, vol. 24(2), pages 694-730, June.
    8. Overesch Michael, 2016. "Steuervermeidung multinationaler Unternehmen," Perspektiven der Wirtschaftspolitik, De Gruyter, vol. 17(2), pages 129-143, July.
    9. Sebastian Beer & Mr. Alexander D Klemm & Ms. Thornton Matheson, 2018. "Tax Spillovers from US Corporate Income Tax Reform," IMF Working Papers 2018/166, International Monetary Fund.
    10. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    11. Dhammika Dharmapala, 2008. "What problems and opportunities are created by tax havens?," Oxford Review of Economic Policy, Oxford University Press and Oxford Review of Economic Policy Limited, vol. 24(4), pages 661-679, winter.
    12. Dhammika Dharmapala, 2020. "Do Multinational Firms Use Tax Havens to the Detriment of Other Countries?," CESifo Working Paper Series 8275, CESifo.
    13. Heckemeyer, Jost H. & Richter, Katharina & Spengel, Christoph, 2014. "Tax planning of R&D intensive multinationals," ZEW Discussion Papers 14-114, ZEW - Leibniz Centre for European Economic Research.
    14. Katarzyna Bilicka & Michael Devereux & Irem Güçeri, 2023. "Tax-Avoidance Networks and the Push for a “Historic” Global Tax Reform," Tax Policy and the Economy, University of Chicago Press, vol. 37(1), pages 57-108.
    15. Wolfram F. Richter, 2017. "Taxing Intellectual Property in the Global Economy: A Plea for Regulated and Internationally Coordinated Profit Splitting," CESifo Working Paper Series 6564, CESifo.
    16. Bronwyn H. Hall, 2020. "Tax Policy for Innovation," NBER Chapters, in: Innovation and Public Policy, pages 151-188, National Bureau of Economic Research, Inc.
    17. Gaessler, Fabian & Hall, Bronwyn H. & Harhoff, Dietmar, 2021. "Should there be lower taxes on patent income?," Research Policy, Elsevier, vol. 50(1).
    18. Ulrich Schreiber, 2015. "Investitionseffekte des BEPS Aktionsplans der OECD," Schmalenbach Journal of Business Research, Springer, vol. 67(1), pages 102-127, February.
    19. Cooper, Maggie & Nguyen, Quyen T.K., 2020. "Multinational enterprises and corporate tax planning: A review of literature and suggestions for a future research agenda," International Business Review, Elsevier, vol. 29(3).
    20. Fuest, Clemens & Spengel, Christoph & Finke, Katharina & Heckemeyer, Jost H. & Nusser, Hannah, 2013. "Profit shifting and 'aggressive' tax planning by multinational firms: Issues and options for reform," ZEW Discussion Papers 13-078, ZEW - Leibniz Centre for European Economic Research.

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:eso:journl:v:50:y:2019:i:2:p:325-340. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Aedin Doris (email available below). General contact details of provider: https://www.esr.ie .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.