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	<title>Comments on: FOREIGN ENTERPRISE IN IRELAND: SOME FIGURES</title>
	<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/</link>
	<description>It's a group blog. What more do you need to know?</description>
	<pubDate>Thu, 24 May 2012 16:15:42 +0000</pubDate>
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		<title>By: Elias</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75317</link>
		<author>Elias</author>
		<pubDate>Tue, 30 Nov 2010 21:11:54 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75317</guid>
		<description>Three quotes from the article, very interesting, thanks Peggy Olson! 

1. ETRs are firms' income tax expense divided by their pre-tax incomes for the year. 

2. Effective rates are the median rates for all publicly-traded companies incorporated (and publicly traded) within that country 
[eg. Google aren't publically traded on the ISEQ]

3. While many countries' ETRs are below the statutory rates, a few have ETRs higher than the statutory rates. This is because the statutory rate only includes the national income tax rate. In contrast, firms' reported ETRs include national, local and foreign taxes paid. For example, Cayman Island companies have median ETRs of under 10 percent, but this is comprised solely of taxes paid to other countries.
I think this table just shows how Irish corporations such as smurfit and roadstone have not benefitted as much from the corporation tax as multinationals.

http://en.wikipedia.org/wiki/Double_Irish_Arrangement
There's a pdf at the bottom of the wiki article with exact details.
There's a HUGE scope for trickery under the above arrangement, common knowledge abroad since 2007.</description>
		<content:encoded><![CDATA[<p>Three quotes from the article, very interesting, thanks Peggy Olson! </p>
<p>1. ETRs are firms&#8217; income tax expense divided by their pre-tax incomes for the year. </p>
<p>2. Effective rates are the median rates for all publicly-traded companies incorporated (and publicly traded) within that country<br />
[eg. Google aren&#8217;t publically traded on the ISEQ]</p>
<p>3. While many countries&#8217; ETRs are below the statutory rates, a few have ETRs higher than the statutory rates. This is because the statutory rate only includes the national income tax rate. In contrast, firms&#8217; reported ETRs include national, local and foreign taxes paid. For example, Cayman Island companies have median ETRs of under 10 percent, but this is comprised solely of taxes paid to other countries.<br />
I think this table just shows how Irish corporations such as smurfit and roadstone have not benefitted as much from the corporation tax as multinationals.</p>
<p><a href="http://en.wikipedia.org/wiki/Double_Irish_Arrangement" rel="nofollow">http://en.wikipedia.org/wiki/Double_Irish_Arrangement</a><br />
There&#8217;s a pdf at the bottom of the wiki article with exact details.<br />
There&#8217;s a HUGE scope for trickery under the above arrangement, common knowledge abroad since 2007.</p>
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		<title>By: RosencrantzisDead</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75304</link>
		<author>RosencrantzisDead</author>
		<pubDate>Sun, 28 Nov 2010 21:04:09 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75304</guid>
		<description>I am confused by the data given by Peggy.

They calculate the effective tax rate for all publicly traded firms in the world. They then provide a breakdown by country of incorporation. It seems to me that the data they are using is for all companies listed as PLCs in Ireland. I might be wrong on this and I am open to correction, but that interpretation gels with what they say in the article provided. I don't think anyone has access to Compustat, so we cannot clear up this issue by looking at the primary data.

If the data is based on firms that are listed as PLCs in Ireland, then this would most likely exclude the vast majority of foreign firms, who generally establish private limited companies in Ireland. This would necessarily exclude subsidiaries of Google, Amazon, Dell etc. from the data, since they are not publicly traded companies incorporated in Ireland; instead, they are private limited companies that are subsidiaries of publicly traded companies incorporated in the US and other jurisdictions. This would undoubtedly have an effect on the stats.</description>
		<content:encoded><![CDATA[<p>I am confused by the data given by Peggy.</p>
<p>They calculate the effective tax rate for all publicly traded firms in the world. They then provide a breakdown by country of incorporation. It seems to me that the data they are using is for all companies listed as PLCs in Ireland. I might be wrong on this and I am open to correction, but that interpretation gels with what they say in the article provided. I don&#8217;t think anyone has access to Compustat, so we cannot clear up this issue by looking at the primary data.</p>
<p>If the data is based on firms that are listed as PLCs in Ireland, then this would most likely exclude the vast majority of foreign firms, who generally establish private limited companies in Ireland. This would necessarily exclude subsidiaries of Google, Amazon, Dell etc. from the data, since they are not publicly traded companies incorporated in Ireland; instead, they are private limited companies that are subsidiaries of publicly traded companies incorporated in the US and other jurisdictions. This would undoubtedly have an effect on the stats.</p>
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		<title>By: Conor McCabe</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75291</link>
		<author>Conor McCabe</author>
		<pubDate>Sat, 27 Nov 2010 19:17:31 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75291</guid>
		<description>Huh? I'm trying to learn here Peggy. 

You said that I am wrong. The evidence you have used to show that I am wrong points to Ireland having an effective corporation tax rate of 15.5%

I'm just saying well done, because it is the first time I have heard this, and it goes against what Bloomberg and the New York Times have been reporting for the past year.

But can you clear this up for me? The €5 billion in corporation tax. How much in taxable profits is that based upon?</description>
		<content:encoded><![CDATA[<p>Huh? I&#8217;m trying to learn here Peggy. </p>
<p>You said that I am wrong. The evidence you have used to show that I am wrong points to Ireland having an effective corporation tax rate of 15.5%</p>
<p>I&#8217;m just saying well done, because it is the first time I have heard this, and it goes against what Bloomberg and the New York Times have been reporting for the past year.</p>
<p>But can you clear this up for me? The €5 billion in corporation tax. How much in taxable profits is that based upon?</p>
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		<title>By: Peggy Olsen</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75290</link>
		<author>Peggy Olsen</author>
		<pubDate>Sat, 27 Nov 2010 19:06:03 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75290</guid>
		<description>&lt;i&gt;But you are saying that it is a more realistic estimate of the effective corporation tax rate, that realisticly speaking Ireland’s corporation tax rate is 15.5%&lt;/i&gt;
Eh, no.
The statutory rate remains at 12.5%.
The effective rate for those 61 companies is 15.5%.
These are just two different measures of the same thing.
Both are generally accepted metrics.
Unlike your definition of the effective rate, which has no currency outside of this blog.
By the way, do you always resort to sarcasm when someone points out where you're wrong?</description>
		<content:encoded><![CDATA[<p><i>But you are saying that it is a more realistic estimate of the effective corporation tax rate, that realisticly speaking Ireland’s corporation tax rate is 15.5%</i><br />
Eh, no.<br />
The statutory rate remains at 12.5%.<br />
The effective rate for those 61 companies is 15.5%.<br />
These are just two different measures of the same thing.<br />
Both are generally accepted metrics.<br />
Unlike your definition of the effective rate, which has no currency outside of this blog.<br />
By the way, do you always resort to sarcasm when someone points out where you&#8217;re wrong?</p>
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		<title>By: Conor McCabe</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75289</link>
		<author>Conor McCabe</author>
		<pubDate>Sat, 27 Nov 2010 18:55:31 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75289</guid>
		<description>But you are saying that it is a more realistic estimate of the effective corporation tax rate, that realisticly speaking Ireland's corporation tax rate is 15.5%

This is ground-breaking stuff here Peggy. Well done. It puts Bloomberg and the New York Times to shame, that's for sure.

How much in taxable profits is the €5 billion in corporation tax based upon? </description>
		<content:encoded><![CDATA[<p>But you are saying that it is a more realistic estimate of the effective corporation tax rate, that realisticly speaking Ireland&#8217;s corporation tax rate is 15.5%</p>
<p>This is ground-breaking stuff here Peggy. Well done. It puts Bloomberg and the New York Times to shame, that&#8217;s for sure.</p>
<p>How much in taxable profits is the €5 billion in corporation tax based upon?</p>
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		<title>By: Peggy Olsen</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75288</link>
		<author>Peggy Olsen</author>
		<pubDate>Sat, 27 Nov 2010 18:45:34 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75288</guid>
		<description>Its not my data, but I can tell you that all 61 are incorporated in Ireland. Not that tells us much about origin, as they could be local personalities of the global company, e.g. Amazon Data Services Ireland Ltd.
Here's the background on the table: http://www.cpa2biz.com/Content/media/PRODUCER_CONTENT/Newsletters/Articles_2008/Tax/juryin.jsp
The idea of the effective rate being greater than the statutory rate is not as whacky as you make out.
In fact, it was discussed in the Dail just last week: http://www.kildarestreet.com/debate/?id=2010-11-23.512.0
Obviously its not a case of the company voluntarily paying "extra tax" in any sense. Instead its an artifact of how taxable profits are calculated versus corporate income statements.</description>
		<content:encoded><![CDATA[<p>Its not my data, but I can tell you that all 61 are incorporated in Ireland. Not that tells us much about origin, as they could be local personalities of the global company, e.g. Amazon Data Services Ireland Ltd.<br />
Here&#8217;s the background on the table: <a href="http://www.cpa2biz.com/Content/media/PRODUCER_CONTENT/Newsletters/Articles_2008/Tax/juryin.jsp" rel="nofollow">http://www.cpa2biz.com/Content/media/PRODUCER_CONTENT/Newsletters/Articles_2008/Tax/juryin.jsp</a><br />
The idea of the effective rate being greater than the statutory rate is not as whacky as you make out.<br />
In fact, it was discussed in the Dail just last week: <a href="http://www.kildarestreet.com/debate/?id=2010-11-23.512.0" rel="nofollow">http://www.kildarestreet.com/debate/?id=2010-11-23.512.0</a><br />
Obviously its not a case of the company voluntarily paying &#8220;extra tax&#8221; in any sense. Instead its an artifact of how taxable profits are calculated versus corporate income statements.</p>
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		<title>By: Conor McCabe</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75287</link>
		<author>Conor McCabe</author>
		<pubDate>Sat, 27 Nov 2010 18:18:42 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75287</guid>
		<description>I meant in the figures you link to, the figures you cite.

I'm particularly interested in the 61 companies you have found that pay an average of 15.5% corporation tax. 

Who are these companies that pay more corporation tax in Ireland than they are legally bound to pay?

And my figure of approx. 3 billion is for IDA-supported companies. </description>
		<content:encoded><![CDATA[<p>I meant in the figures you link to, the figures you cite.</p>
<p>I&#8217;m particularly interested in the 61 companies you have found that pay an average of 15.5% corporation tax. </p>
<p>Who are these companies that pay more corporation tax in Ireland than they are legally bound to pay?</p>
<p>And my figure of approx. 3 billion is for IDA-supported companies.</p>
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		<title>By: Peggy Olsen</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75286</link>
		<author>Peggy Olsen</author>
		<pubDate>Sat, 27 Nov 2010 18:14:23 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75286</guid>
		<description>Total corpo tax receipts in '08 were 5.065 billion.
You calculated the foreign element of that in the same year as 3 billion.
So that would give a circa 60:40% split between foreign and native.</description>
		<content:encoded><![CDATA[<p>Total corpo tax receipts in &#8216;08 were 5.065 billion.<br />
You calculated the foreign element of that in the same year as 3 billion.<br />
So that would give a circa 60:40% split between foreign and native.</p>
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		<title>By: Conor McCabe</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75285</link>
		<author>Conor McCabe</author>
		<pubDate>Sat, 27 Nov 2010 17:46:18 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75285</guid>
		<description>What's the breakdown between coporation tax paid by indigenous companies and corporation tax paid by foreign companies?</description>
		<content:encoded><![CDATA[<p>What&#8217;s the breakdown between coporation tax paid by indigenous companies and corporation tax paid by foreign companies?</p>
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		<title>By: Peggy Olsen</title>
		<link>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75284</link>
		<author>Peggy Olsen</author>
		<pubDate>Sat, 27 Nov 2010 17:39:08 +0000</pubDate>
		<guid>http://dublinopinion.com/2010/11/25/foreign-enterprise-in-ireland-manufacturing/#comment-75284</guid>
		<description>Oh your arithmetic is perfectly fine, if that's what you mean. I'm sure you checked it on a calculator.
But you're just using the wrong numbers.
Here's a more realistic estimate of the effective rates across a range of countries, including ourselves: https://media.cpa2biz.com/newsletter/2008/Tax/july/juryin_table.htm Note the effective rate is estimated as being &lt;i&gt;higher&lt;/i&gt; than the statutory rate in our case.
Also, you might want to consider the corpo-tax:GDP ratio in a few other countries to see if we're totally off the map: http://www.scribd.com/doc/41827087/Corp-Tax</description>
		<content:encoded><![CDATA[<p>Oh your arithmetic is perfectly fine, if that&#8217;s what you mean. I&#8217;m sure you checked it on a calculator.<br />
But you&#8217;re just using the wrong numbers.<br />
Here&#8217;s a more realistic estimate of the effective rates across a range of countries, including ourselves: <a href="https://media.cpa2biz.com/newsletter/2008/Tax/july/juryin_table.htm" rel="nofollow">https://media.cpa2biz.com/newsletter/2008/Tax/july/juryin_table.htm</a> Note the effective rate is estimated as being <i>higher</i> than the statutory rate in our case.<br />
Also, you might want to consider the corpo-tax:GDP ratio in a few other countries to see if we&#8217;re totally off the map: <a href="http://www.scribd.com/doc/41827087/Corp-Tax" rel="nofollow">http://www.scribd.com/doc/41827087/Corp-Tax</a></p>
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