Tuesday, October 15, 2013

Moving to stop “stateless” profits

Included among the budget documents is a short release on Ireland’s International Tax Strategy.  There is not a lot new in it but it does signal that the ability of companies such as Apple to create “stateless” profits or “ocean money” will be curtailed.

The second measure to be included in the Finance Bill is a change to our company residence rules aimed at eliminating mismatches - that can exist between tax treaty partners in certain circumstances – being used to allow companies to be ‘stateless’ in terms of their place of tax residence.

This was signalled here yesterday towards the end of a post on corporation tax:

We are probably not going to hear much at this level of detail in tomorrow’s budget but the Finance Act, 2014 may look to disassociate Ireland from the “ocean money” created by Apple.

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