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Corporation Tax Residence: Is Ireland Exceptional ?

Author

Listed:
  • Jim Stewart

    (Institute for International Integration Studies, Trinity College Dublin)

Abstract

There has been extensive criticism of the use of US Bureau of Economic Analysis (BEA) to estimate effective tax rates for US companies operating in Ireland. The BEA data uses place of incorporation as the location of a firm. In contrast Revenue Commissioners data, excludes firms that are incorporated in Ireland but not resident for corporate tax purposes, in estimates of aggregate profits. Omitting profits of firms that are not tax resident (bi-located), reduces measures of aggregate profits and measures of effective tax rates. This exclusion is important. Just two firms incorporated in Ireland but regarded as not resident for corporate tax purposes (subsidiaries of Apple and Google), reported pre tax profits of €22.23 billion in 2011. This paper shows that on several objective criteria these firms are located in Ireland and hence it is reasonable to include their profits in measures of aggregate corporate profits in Ireland.

Suggested Citation

  • Jim Stewart, 2014. "Corporation Tax Residence: Is Ireland Exceptional ?," The Institute for International Integration Studies Discussion Paper Series iiisdp449, IIIS.
    • Handle: RePEc:iis:dispap:iiisdp449
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    More about this item

    Keywords

    Residence for corporate tax purposes; Irish tax regime; corporate tax reform;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K23 - Law and Economics - - Regulation and Business Law - - - Regulated Industries and Administrative Law
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • L - Industrial Organization
    • O25 - Economic Development, Innovation, Technological Change, and Growth - - Development Planning and Policy - - - Industrial Policy

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