Monday, August 17, 2020

Improvement in net worth per capita stalls

There are lots of things that can go on a national balance sheet.  National accounts can give one perspective.  As set out in a previous post there this gives essentially four things that can go on the national balance sheet:

  • Financial assets (such as deposits, equity and pension savings), and
  • Financial liabilities (such as loans)
  • Produced fixed assets (such as buildings, infrastructure, equipment and IP)
  • Non-produced fixed assets (such as land)

There is lots of detail on these in the previous post.  For now we’ll just update (to 2018 for most countries) the net worth per capita chart for the EU15 (ex Lux).  This is based on the first three items above, i.e. the value of non-produced fixed assets such as land is excluded.

National Balance Sheet EU15 Net Worth Per Capita 2001-2018

Ireland’s net worth per capita displays a volatility that is not present for the other countries in the chart.  Excluding Luxembourg, Ireland had the third-highest nominal net worth per capita in the EU15 in 2006. 

This, of course, was based on property prices which had been unsustainably boosted by a credit bubble. By 2011, Ireland had the lowest net worth per capita of the selected group.  It was only in 2015, that Ireland’s per capita net worth began in to rise.  As can be seen this slowed in 2017 and actually reversed in 2018 leaving Ireland with the fifth-lowest nominal net worth per capita.

One of the issues with Ireland’s balance sheet is that some of the the gross amounts are immense relative to the size of the economy. 

For example, total economy financial assets and liabilities were each in the vicinity of €7 trillion at the end of 2018.  We also know that the fixed assets side has its quirks.  Included are hundreds of billions worth on aircraft for leasing and IP of US MNCs.

Small movements in these, most of which have little direct impact on the well-being of Irish residents, can have significant effects on net outcomes and even more so in per capital terms.  In the main though, we can expect this issues to net out.  Financial liabilities of the IFSC are offset by related financial assets and the aircraft and IP assets have offsetting financial liabilities.

One reason why Ireland’s net worth per capita stalled in 2018 is because the improvement in the household financial balance sheet stalled somewhat in 2018. 

Household Sector Balance Sheet 2017-18

Yes, deposits rose and loans fell as would be expected but contrary moves in the value of listed shares held and insurance technical reserves meant there was little change in the net financial worth of the household sector in 2018.  The value of assets such as dwellings which are included in the initial chart are excluded from this table while, as noted, the value of land is wholly excluded here.

Maybe there will be some bounceback in the 2019 figures but the gap to the next-ranked country in 2018 (Italy) suggests that Ireland will remain as having the fifth-lowest nominal net worth per capita in the EU15.

Tuesday, August 11, 2020

Further insights into Apple’s use of capital allowances

Apple Operations International is the Irish-registered Apple subsidiary that sits at the top of the companies that form Apple’s structure outside the Americas.  Previously as an unlimited company it did not have to file financial statements with the Companies Registration Office.

Recent legislative changes mean this is no longer the case and unlimited companies must now publish accounts.  This time last year consolidated 2018 accounts for Apple Operations International and all the companies beneath it were published.  See our discussion here with link to original post on Apple’s post-2015 revised structure. 

The 2019 accounts have now been published (which show that AOI has re-registered as a limited company).  There is lots of detail in the accounts but we will focus on the provision for income taxes in the statement of operations, payments for income taxes in the statement of cash flows and deferred tax assets on the balance sheet.

First the AOI Group’s consolidated income statement where the first thing we notice is that it looks like the company has bought a better scanner:

AOI Income Statement 2019

Of the $141 billion of net sales in 2019, $120 billion came from the sale of products with the remainder due to services.  The AOI group is hugely profitable.  In its 2018 financial year it had an income before income taxes of $46.7 billion.  It was down a bit in 2019 but was still $41.7 billion. 

As outlined previously the primary reason for this is the cost-sharing agreement (CSA) the AOI group has entered with Apple Inc. which provides the AOI group with a license to sell Apple products and use Apple Inc.’s intellectual property outside the Americas. 

To get the license the AOI group makes a cost-share payment to Apple Inc.  The cost to be shared is the R&D expense incurred with the share set relative to the size of the market the participant to the CSA sells into.  Sales outside the Americas make up slightly more than 50 per cent of Apple’s overall sales so the AOI group makes a payment to cover roughly 50 per cent of the overall R&D expense incurred by Apple.

As can be seen above the AOI group had an R&D expense of $7.2 billion in 2018 and $7.6 billion in 2019, and these are close to half of the total R&D expense incurred by Apple.  However, as the table above shows the right to sell Apple’s products and use Apple’s IP is worth much more than this. 

The value comes from the product innovation, R&D, brand development etc., which is carried out by Apple Inc. in the US but through the cost-sharing agreement Apple Inc. transfers this value to the AOI group. 

A profit-share agreement based on royalties would seem like a much more likely type of agreement for someone who is doing all the innovation and research to enter into but such cost-share agreements are allowed under the approach to transfer pricing set out in the US tax code.

Indeed, the IRS has challenged the terms of a number of these transfers used by other US companies, including Amazon and Facebook, but has yet to record a significant win in the US tax courts. 

In principle, the AOI group should be paying much more for the right to sell Apple products outside the Americas. And the US tax code even encourages such profit shifting.  Up to the end of 2017 this was through the deferral provisions there were then in the US tax code. 

Since the Tax Cuts and Jobs Act of December 2017 it is through different rates.  The headline rate of the federal corporate income tax is 21 per cent but lower rates are available via the FDII and GILTI provisions now in the US tax code.  FDII is Foreign-Derived Intangible Income and GILTI is Global Intangible Low-Taxed Income and is the one relevant here.

Anyway, let’s get back to our focus: the taxation of the AOI group.  We can see from the income statement that the AOI group made a provision for income taxes of  $6.7 billion in 2018 and $6.2 billion in 2019.  These correspond to effective accounting tax rates of 14.2 per cent and 14.9 per cent.

Although the AOI group is made up of around 70 subsidiaries with activities right around the world (and 47,000 employees) it does appear that most of the profit of the group is subject to tax in Ireland.  Here is a table that reconciles the above effective tax rates with Ireland’s headline 12.5 per cent rate.

AOI Provision for Income Taxes Notes 2019

In both years, the largest item explaining why the provision is greater than what the 12.5 per cent rate would imply is “Other” which is not very insightful at all.  We can see that both years have a positive figure for “differences in effective tax rates on overseas earnings”. 

In this instance overseas means outside Ireland.  Most jurisdictions have higher rates of corporate taxes than Ireland but the impact on the tax provision for the AOI group seems relatively modest: $150 million in 2018 and $352 million in 2019.  These are net figures so could be reduced by overseas earnings taxes at less than 12.5 per cent but the assumption that most of the income is subject to tax in Ireland is probably fairly safe.

However, a company making a provision for income taxes in its accounts is not the same as a company actually making a tax payment to a government.  Indeed, the cash flow statement in the accounts provides figures for “cash paid for income taxes, net”.  This was $1,418 million in 2018 and $2,229 million in 2019. 

So while the company does pay tax, these figures of $1.4 billion and $2.2 billion are obviously much less than the provisions for income taxes which were north of $6 billion in both years.  While timing can be an issue for temporary differences between the these figures the accounts point us to the reason for the large difference we see in this case.

AOI Provision for Income Taxes Notes 2019 2

Here we get a decomposition of the provision for income taxes into “current income tax” and “deferred income tax”.  Current tax is the tax charge for the period that will be paid.  Now, there may be a slight delay due to when tax returns are filed and the transfers actually made. 

For example, an Irish company with an end-September year-end would make interim Corporation Tax payments in March and August and would have until the following June to file its tax return and pay the final amount.  Anyway, it’s safe enough to take “current income tax” as tax that was been paid during the period in question or will be paid shortly after the year end.

On the other hand we have deferred tax.  This could lead to a deferred tax liability which would have a payment triggered in the future.  Alternatively, a company could previously have had a tax benefit on its income tax statement and the deferred income tax could be the reversal of that.  No payment will be made in the future.  This is the utilisation of a previously-generated deferred tax asset.

This could due to prior losses which can be carried forward for tax purposes.  But we have to go back to the 1990s for the last time Apple was loss making.  As we have shown previously Apple generated significant tax benefits using Section 291A of the Taxes Consolidated Act.

The participating companies are all likely to be part of the AOI group but one company in the group bought the license to sell Apple’s products outside the Americas from another company in the group.  The acquiring company became Irish resident and the expenditure it incurred in acquiring the license (likely to be something around €200 billion) is deductible for Corporation Tax purposes.

This is done through capital allowances -  a certain amount of the expenses incurred related to the asset (acquisition, financing and maintenance) can be used each year as a deduction when determining taxable income.  The AOI group would have recorded a large tax benefit when the transaction was undertaken in 2015.   This tax benefit would probably have been in the region of €25 billion (€200 billion x 0.125).

The amount for deferred income tax in the above table is the utilisation of that tax benefit.  Accounting standards may require it to be called a “deferred” tax expense but in the context here it will never be paid.  It is simply the accounting treatment of the taxation of acquired intangible assets as set out in S291A.

And, to no surprise, the balance sheet of the AOI group shows a deferred tax asset. 

AOI Balance Sheet Assets 2019

The liability side does not show an item for deferred tax liabilities.  The accounts have a table that show how the deferred tax assets have evolved over the past few years.

AOI Deferred Tax Assets 2019

We are primarily interested in those related to “intra-group transactions”.  We can see that these were $18.2 billion in September 2017, were reduced by $4.4 billion in the year to September 2018 to $13.8 billion and were reduced by a further $3.2 billion to reach $10.6 billion in September 2019.  

It seems likely that deferred tax assets from intra-group transactions will have been reduced by around $3-4 billion in the 12 months since and at current rate of utilisation will be exhausted in another two years unless additional expenditure is incurred.

This means that taxable income in Ireland will be reduced by around €25 billion using the capital allowances, while available.  The following extract from AOI’s accounts is worth nothing:

The corporate income taxes in the consolidated statements of operations, balance sheets and statement of cash flows do not include significant US-level corporate taxes borne by Apple Inc., the ultimate parent of the group.
US-level taxes are paid by Apple Inc. on investment income of the Group at the rate of 24.5% (35.0% in 2017) net of applicable foreign tax credits. In addition, under changes in US tax legislation that took effect in December 2017, Apple Inc. is subject to tax on previously deferred foreign income (at a rate of 15.5% on cash and certain other net assets and 8.0% on the remaining income), net of applicable foreign tax credits.  The new legislation also subjects certain current foreign earnings of the Group to a new minimum tax.

The final sentence is a reference to the new GILTI provisions in the US tax code.  Any reduction in Irish Corporation Tax within the AOI group using capital allowances will be made up via a higher tax payment to the US by Apple Inc.  And any payment of non-US tax on the intangible income will result in the company getting a credit equal to 80 per cent of the non-US tax paid to offset against its US GILTI liability.

Of course, as noted above, we are getting closer to the point where the capital allowances from Apple’s massive transaction at the start of 2015 will be exhausted.  What will happen then?  If this income continues to be recorded in Ireland then there will be no deferred tax asset to offset the current tax liability. 

If nothing changes this could see Apple pay an additional €3 billion or so of Irish Corporation tax while seeing its US tax bill fall by a near commensurate amount.  If nothing changes.

Thursday, July 30, 2020

The at-risk-of-poverty rate for children

The at-risk-of-poverty rate is an important indicator.  The chart below shows the share of children living in households who had an equivalised disposable income that was less than 60 per cent of the national median for the countries of the EU15 from 2004 to 2018.

EU15 SILC AROP Children 0-17 2004-2018

In 2018, the rate for Ireland was 15.8 per cent and puts it at its the lowest recorded level and was the fifth-lowest in the EU15.  Indeed if we look at the changes since 2004/05 we see that Ireland has seen the greatest reduction in the at-risk-of-poverty rate for children within this group of countries.

EU15 SILC AROP Children 0-17 Change 2004 to 2018

As the chart shows, the AROP rate for children aged under 18 has fallen by 7 percentage points in Ireland over the last 15 years (22.8 per cent to 15.8 per cent).  At the other end this compares to an increase of a similar magnitude for Sweden.

It could be that the first chart does not seem to fit with what we might expect.  Yes, there are reductions in periods of strong growth (2006-07 and 2017-18) but where is the crash of 2008 and the subsequent period of austerity?  For the ten years from 2008, Ireland’s at-risk-of-poverty rate for children was pretty much unchanged but this was a time of significant changes.

One of the reasons for this is that the at-risk-of-poverty rate is a relative measure: it is assessed against a moving target – the national median equivalised disposable income.  The threshold against which being at-risk-of-poverty is assessed will change based on how the national median income changes.

EU15 SILC AROP Threshold 2 2 Household 2005-2018

In 2008, for example, the at-risk-of-poverty threshold used by Eurostat for a two adult plus two children under 14 household in Ireland was around €29,000.  In the following years as the impact of the crash and austerity was felt virtually all incomes fell which meant that the median income, or midpoint of the income distribution, also fell. 

By 2011, the AROP threshold for a 2+2 household had fallen below €25,000.  This reduction in the threshold meant the AROP did not reflect the increased difficulties faced by many households.  The median income threshold began to rise in 2014 and by 2018 the threshold for a 2+2 household exceeded €31,000. 

This means deteriorations and improvements can be partly masked and not fully show in the at-risk-of-poverty rate and emphasizes that, while having poverty in it’s name, it is as much a measure of inequality.

We can get closer to a measure that reflects changes in absolute poverty by anchoring the threshold at a fixed point and examining the share of people which are below that fixed threshold (after adjusting for inflation).

EU15 SILC AROP Anchored Children 0-17 2004-2018

The pattern of the anchored at-risk-of-poverty rate for Ireland probably better reflects our prior expectations with a clear deterioration evident from 2009 to 2012.  Relative to its 2005 threshold adjusted for inflation no country has seen a larger reduction in its anchored at-risk-of-poverty rate

EU15 SILC AROP Children 0-17 Anchored Change 2004 to 2018

Greece went “off the scales” in the previous chart here we can see that its anchored AROP rate in 2018 was nearly 27 percentage points higher than it was in 2005.  Most countries show a reduction though for some it is relatively minor while no data on this measure is available for France.

An important consideration when assessing at-risk-of-poverty rates is the role of social transfers.  While Ireland in 2018 had an AROP rate for children that was significantly less than it was in 2005, if we look at the AROP rate before social transfers it has been at pretty the same rate for the past few years that it was from 2005 to 2008, i.e. in or around 40 per cent. 

EU15 SILC AROP before Transfers Children 0-17 2004-2018

Ireland’s AROP before social transfers for children has been close to the highest in what was the EU15.  Although it is at the level it was pre-2008 it has been on a fairly steady downward trend since 2011.  The changes in the previous chart are of a similar magnitude to the changes shown below for the share of children living in households where there is very little paid employment undertaken.

EU15 SILC VLWI Children 0-17 2004-2018

For every year for which data is available Ireland has had the highest share of children living in quasi-jobless households – households where the adults of working age are in paid employment for less than 20 per cent of the available time.

Eurostat also provide a measure of the at-risk-of-poverty rate after deducting housing costs from disposable income.  The threshold is left unchanged but the benchmark is assessed against the adjusted income of the household.

For Ireland this stood at 29.7 per cent in 2018 and has been showing a slight downward trend in recent years.

EU15 SILC AROP after Housing Costs Children 0-17 2004-2018

A related measure is the housing cost overburden rate.  This is the share of people living in households who face a total housing cost that is greater than 40 per cent of the household’s disposable income.  Here it is for children aged 0 to 17 years.

EU15 SILC Housing Cost Overburden Rate Children 0-17 2005-2018

Once again, Greece goes off the chart and in 2018 had a rate of 48 per cent which was almost three times greater than the second highest (the UK at 17 per cent).  The rate in Ireland in 2018 was 3.2 per cent which was the third-lowest in the EU15. 

It should also be noted that while mortgage interest payments are included by Eurostat in total housing costs for owner-occupiers mortgage principal repayments are excluded.  Of course, it may be that Ireland’s housing problems are preventing some from entering this category so it would be unwise to view Ireland’s position in a universally positive light.

And this may be evidenced when we look at the at-risk-of-poverty rate for young children:

EU15 SILC AROP Children 0-5 2004-2018

In 2018, Ireland had the lowest at-risk-of-poverty rate for children aged under six.  The sample size may be small so there may be a lack of precision in the estimates but it can be seen that the rate dropped from 17 per cent in 2016 to 9 per cent in 2018.

Now, we could interpret that as being the result of a very rapid rise in the incomes of households with young children.  From 2016 to 2018 the AROP threshold rose by 10 per cent so incomes would have to rise by that much just to match the rising threshold and it would take a much faster rise again to almost halve the AROP rate.

But maybe as well as the standard errors of the estimate could there also be a sample selection issue.  Maybe it is not that the incomes of households with young children are rising rapidly but that those households with young children have higher incomes.  Obviously, we can’t tell something like that from this aggregate data but with housing issues possibly delaying household formation and childcare issues resulting in high costs we should again caution against taking a universally positive view of Ireland’s position in the previous chart.

A hint that as is not as it might seem can be found by looking at the material and social deprivation rate.  This is the percentage of people in households experiencing at least five from a list of 13 items.  This is a relatively recent measure so a time series back to the early 2000s in not available.  Here it is for children aged less than six for the countries of the EU15 since 2014.

EU15 SILC Material and Social Deprivation Rate Children 0-5 2014-2019

So, while Ireland might have had lowest AROP for children under six in the EU15 in 2018, Ireland also had the fifth-highest rate of children in this age group living in housing experiencing material and social deprivation.

To conclude here is the persistent at-risk-of-poverty rate for children under under 18.  This is the share of children who are in an at-risk-of-poverty household this year who were also in this position for at least two of the previous three years.

EU15 SILC AROP Persistent Children 0-17 2007-2018

Again, some sample sizes affects precision and it can be seen that the estimates show a good deal of volatility.  In any given year, a maximum of 25 per cent of the sample from four years remain in the survey.  The survey design is such that a household remains in the survey for four years so one quarter of the sample is replaced each year.  Of course, the numbers exiting will be higher for a variety of reasons (household changes, non response etc.)

And for the above it is further limited to household who had children under 18 in the current year.  Still, recent estimates for Ireland are pretty steady and show that around 10 per cent of children are in households whose income is persistently below the relative at-risk-of-poverty threshold.

Thursday, July 23, 2020

The Modified Current Account in 2019

The CSO have published the details of CA*, Ireland’s current account of the balance of payments modified for some of the effects of MNCs.  The reported outturn for 2019 is pretty remarkable – a surplus of €16.5 billion (8.8% of its sister measure of national income, GNI*).  As the estimates of Fitzgerald and Kenny (2017) show the last time Ireland recorded a surplus of this magnitude was during World War II.

Current Account 1937-2019

If we combine the current account with the sector accounts we can assess the reasons for the increases in recent years.  Here it is since 2009.

Modified Current Account 2009-2019 by Sector

As was the case in 2018, all sectors have the economy in 2019 recorded positive outturns for S – I (gross savings minus gross capital formation).  Both the government and the household sectors increased their surpluses which is in line with expectations.  The negative “non-sectorised” item arises  in Ireland’s national accounts due to the differences between the income and expenditure methods of estimating GDP.  The discrepancy between the approaches is not attributed to any sector.

Of course, the most notable sector in recent years is the non-financial corporate.  In this instance it is the overall NFC sector with all the “star” adjustments applied to it.  Later in the year we will get a more formal split of the NFC sector into domestic, foreign and re-domiciled.

As we pointed out when these figures were released last year there is something going on with domestic non-financial corporates, and particularly the retained earnings of their foreign FDI and maybe some link to their exploding balance sheet.  When the 2019 figures are released we will see if this continued to have an effect in 2019.  The figures above suggest it did.

All-in-all though the figures for the modified current account are a positive indicator for the Irish economy.  It suggests we do have capacity to respond to the crisis.  And even absent a pandemic there might be reason to look for increased spending (more house building perhaps) to reduce the CA* surplus.

Monday, July 13, 2020

The 2018 Aggregate Corporation Tax Calculation

The Revenue Commissioners have published the 2018 uptake of their aggregate summary of corporation tax returns.  The last of these would have been filed last September and the aggregate data is now available.  As previously, we will look at the outcomes in two stages:

  1. The determination of Taxable Income from Gross Trading Profits, and
  2. The determination of Tax Due from Gross Tax Due

So, lets look at the determination of Taxable Income for the five years from 2014 to 2018.

Aggregate CT Calculation for Taxable Income 2014-2018

In 2015, Irish GDP jumped by around 30 per cent in nominal terms and there’s a lot of action in the first annual change shown in the table.  The unusual GDP increase was primarily the result of the near €50 billion increase in Gross Trading Profits that happened that year.

If we jump down to the bottom of the table we see that that €50 billion increase in Gross Trading Profits only translated into increase in Taxable Income of less than €15 billion.  The main reason for this was the jump in the use of Capital Allowances.  In 2014, €18.6 billion of capital allowances was used against gross trading profit; in 2015 this was €46.2 billion. 

As is well understood this increase was due to increased claims for capital allowances for intangible assets.  Irish resident firms have been making significant capital outlays to buy intangible assets and this expenditure is offset against trading profit as a capital allowance in the determination of Taxable Income.

After 2015, Taxable Income continued to rise recording increases of €6 billion, €8 billion and €16 billion over the next three years.  The 2018 rise was the largest on record.

For the past couple of years we note a couple of things from further up the table:

  • The ongoing rise in the use of capital allowances;
  • The continued level of losses carried forward being used;
  • The increase in foreign income included in Irish CT returns;
  • The decrease in deductions for trade charges; and
  • The level of relief claimed for interest under Section 247.

We may take a closer look at some of these in due course.  For now, we note that after all the adding and subtracting we end up with a figure of €96 billion for Taxable Income in 2018. 

Of this, €87 billion arises from income that is subject to tax at 12.5 per cent (including capital gains which are regrossed to reflect the higher rate of CGT) and €9 billion is income taxed at 25 per cent (mainly non-trading income). 

Although not explicit from the figures it seems likely that the increase in income taxed at 25 per cent relates for foreign income of Irish resident companies.  Net foreign dividend income fell from €8.7 billion in 2017 to €4.5 billion in 2018, while total foreign income rose from €11.4 billion in 2017 to €12.2 billion in 2018.  In most cases, as a result of tax paid abroad, little additional tax is due in Ireland on this foreign-sourced income. 

We can get some insight into this if we look at the second part of the aggregate CT calculation: the transition from Gross Tax Due to Tax Due:

Aggregate CT Calculation for Tax Due 2014-2018

Multiplying the taxable figures by the applicable tax rate gives the starting point of Gross Tax Due (€87 billion x 12.5% plus €9 billion x 25%). 

Ireland had a limited number of reliefs from Corporation Tax.  By far the most significant is the relief for foreign tax paid on foreign income.  Ireland has a worldwide regime for the taxation of resident companies.  They must include all their income in the Irish CT return wherever earned. 

To avoid double taxation, relief is granted for foreign tax paid.  If the amount of foreign tax paid is less than the amount that would be due in Ireland (at the 12.5% or 25% rate) the company makes an Irish tax payment to bring the total tax paid up to the required amount.  In practice very little additional tax is due in Ireland.

We can see that Double Taxation Relief and the Additional Foreign Tax Credit were almost €2.2 billion in 2018.  At 12.5 per cent this amount of tax relief would correspond to an income of €18.4 billion.  As we say above, foreign income in 2018 was €12.2 billion so it must be that a large share of the foreign income is income that would be subject to tax at 25 per cent, and has double taxation relief applied accordingly.

After tax reliefs, we see that tax payable in 2018 was €10.9 billion.  As per reliefs, Ireland has a relatively small number of tax credits that can be used to reduce CT payments.  The most significant of these is the R&D tax credit though the cost of claims has fallen in recent years.

In 2016, the R&D credit and the repayment of excess R&D credits when the credit exceeded the starting liability summed summed to €670 million.  For 2018 this had reduced to €355 million.

The item Gross Withholding Tax on Fees is simply the granting of credit for tax that has already been paid to the Revenue Commissioners.  The tax code includes a number of instances where the payment of an invoice requires some of the fee to be withheld and paid to the Revenue Commissioners.  Typically this is 20 per cent of the amount due (reflecting the standard rate of Income Tax). 

The person/company paying the invoice withholds the required amount from the provider of the services and transfers the money to the Revenue Commissioners along with the intended recipient’s tax details.  The person/company from home the fee is withheld can then claim credit for the tax paid on their behalf.  The line for Gross Withholding Tax on Fees reflects this tax that has already been paid.

For all CT returns filed for periods ending in 2018, companies had a tax due amount of €10.2 billion.  As indicated in the recent Revenue paper this equates to an effective tax rate of 10.6 per cent ((€10,211 million / €96,049 million) x 100).

However, as we have seen, while there was a €3 billion difference between Gross Tax Due and Tax Due in 2018, €2.5 billion of this was because of tax already paid, either tax paid in other jurisdictions or amounts withheld from fees. 

If there had been no foreign tax paid or fees withheld for tax then the Tax Due on the €96 billion of Taxable Income reported in 2018 CT returns would have been €12.7 billion, an effective rate of 13.2 per cent.

As it was companies did pay tax to other jurisdictions on their foreign source income and did have fees withheld and transferred to the Revenue Commissioners on their behalf.  This means that the amount of Tax Due was reduced but the tax burden imposed by the Irish regime should take into account amounts already paid.

Anyway, whatever way it’s dressed up, Corporation Tax receipts was increased significantly in recent years.  In subsequent posts we will come back to some of the “big ticket” items in the top first part of the CT calculation.