 Corporation Tax Residence: Is Ireland Exceptional ?Jim Stewart ()
The Institute for International Integration Studies Discussion Paper Series from IIIS 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. Keywords: Residence for corporate tax purposes; Irish tax regime; corporate tax reform (search for similar items in EconPapers) Downloads: (external link) Related works: Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text Persistent link: https://EconPapers.repec.org/RePEc:iis:dispap:iiisdp449 Access Statistics for this paper More papers in The Institute for International Integration Studies Discussion Paper Series from IIIS 01. Contact information at EDIRC. |
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