Ireland’s Burgeoning Current Account Surplus and the ‘Statistical Discrepancy’ in the National Accounts

The current account of the balance of payments is an important macroeconomic indicator.  As with many of Ireland’s macroeconomic statistics the underlying picture is distorted by the activities of MNCs.  The modified current account, CA*, is an attempt to overcome this and the CSO will publish the 2021 estimate over the coming weeks.

As with last year, we can look to the sector accounts to try and get a preliminary perspective on where the current account might be going.  Again, at this stage we will limit the analysis to the household and government sectors are these are the least impacted by the MNC distortions but have seen some significant pandemic-related changes in recent years.

Over the twenty years shown, this paints a picture we are pretty familiar with.  More recently, the household sector has been running a large surplus as savings soared.  On the other hand the government has seen large deficits as spending increased in response to the pandemic.  The chart shows gross savings (income not used for consumption) minus investment (capital formation). 

The preliminary figures in the quarterly sector accounts are that for 2021 the combined household plus government sectors had a surplus of savings over investment of €14.6 billion.  This will contribute to a significant current account surplus for 2021.

For 2020, the equivalent figure for the two sectors was a surplus of €8.7 billion.  However, when the contribution of the other sectors of the economy (the corporate sectors) were added, the estimate of the modified current account for 2020 was €24.0 billion.

As was considered here after the results were published this seemed a bit excessive.  There is no doubt that Ireland is running a large current account surplus, but one this is equivalent to 11.5 per cent of national income?

We can use the 2020 Institutional Sector Accounts to get some insights into the sources of this surplus.

Obviously 2020 was a tumultuous year but the increased deficit of the government sector was offset by the surplus of the household sector.  Given what was going on the changes for the domestic corporate sectors both non-financial and financial are relatively modest. 

In this chart, the category for foreign corporations/redomiciled PLCs is a residual that makes the breakout by sector consistent with the estimate of the modified current account.  Although positive, the contribution of this element to the current account fell in 2020 so doesn’t seem to tie in with efforts to explain a burgeoning current account surplus.

What may be worth looking at is the light grey segments of the bars.  This is the “not sectorised” part of the current account.  As set out here, this item arises in Ireland’s national accounts due to the discrepancy that typically exists between the income and expenditure estimates of GDP produced by the CSO.  The official estimate of Ireland’s GDP is essentially the average of the two approaches.  If the figures are close to each other this discrepancy will be small.  However, it is perhaps not a surprise that it can be large – and volatile.

The following table shows the estimates of GDP from the income and expenditure approaches for 2015 to 2020.  Start at the top of the table for the income approach (wages plus profit plus net product taxes).  And go from the bottom of the table for the expenditure approach (C + I + G + X – M).  The official GDP estimate is the midpoint of the two.

As can be seen, for 2020, the income approach gave a GDP estimate of €369.7 billion while that for the expenditure approach was higher at €376.1 billion.  This €6.4 billion difference is resolved by a €3.2 billion “statistical discrepancy” on either side.

This position was the reverse of 2019 when the estimate of the income approach exceeded the estimate from the expenditure approach.  In overall terms, the income estimate went from being €4.0 billion more than the expenditure estimate in 2020 to being €6.4 billion less than it in 2020. All told, this resulted in a €10.4 billion swing in the impact of the “statistical discrepancy” between the two years.

In most instances, given the scale of the figures involved, the statistical discrepancy is not a significant factor.  However, as we work down the accounts and get to things like the current account then it can be significant relevant to the size of those outcomes.  And if we go further again and looked at a sectoral breakdown of the current account then these changes are certainly significant.  In the previous chart, the change in the contribution of “not sectorised” to the current account from 2019 to 2010 was the €10.4 billion referred to above.

Just because something is “not sectorised” doesn’t mean that it doesn’t exist; it’s just that the figures don’t give any insight into what it actually is.  There is some reason why the 2020 growth of the expenditure estimate (6.1 per cent) was much stronger.  It could be that there was an underestimate in 2019 and this is something that the statistical discrepancy allows for.

Or maybe there was something missing from the income approach estimate for 2020 that dragged down its growth rate (3.1 per cent).  Again, this is something that the statistical discrepancy allows for.

Of course, if it was known what was causing the divergence between the figures it would just be included.  The statistical discrepancy arises because it is not known what is causing it.  Have we any reason to put more weight on the income or expenditure estimates of GDP? Not from this remove at any rate.

What it does do is give pause for thought where there are references to a current account surplus of close to one-eighth of national income.  For sure, there is a current account surplus and it does give scope for additional spending (by who?) but maybe we should be looking at average over a number of years rather than being fixated on the estimate for any one year. 

Over the six years shown in the table above, the annual average for difference between the GDP estimates from the income and expenditure approaches is less than €300 million, or pretty much nothing in the context of a GDP number that now exceeds €400 billion. 

This may give some credence to a view that there is nothing systematic going on.  However, it should be noted that the preliminary 2021 figures in the quarterly national accounts show a statistical discrepancy of a similar magnitude and direction to 2020.

So, what we have seen for the household and government sectors and not sectorised all point to another large CA* estimate in the forthcoming release.  Of course, these are preliminary figures and may be revised when the full National Income and Expenditure results are published.  But if measurement issues aren’t enough to dispel any complacency, don’t forget the lurking impact that corporation tax revenues are having on the current account.

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The Continuing Improvement of the National Balance Sheet

Ireland’s national balance sheet has gross amounts and a volatility that is not seen in the figures for most other countries.  The gross amounts are due to the impact of MNCs and the IFSC but do largely net out.  The volatility is partly due to the roller-coaster house prices have taken in recent decades.  When worked through this is what emerges for net worth per capita.

Housing plays a role but does not fully account for the changes shown.  The per capita value of the stock of dwellings (excluding site value) went from €35k in 2001 to €67k in 2006 and then fell to €43k in 2010 before rising back to €60k in 2020.

There are some items not included in the figures published by the CSO.  Not only is the site value for dwellings excluded but the value of all land is excluded.  The CSO does not provide figures for the stock of non-produced, non-financial assets.

The inclusion of such figures would certainly change the level in the chart and also perhaps some of the changes.  Land is the most significant non-produced, non financial asset but there are others.  This useful note from the CSO sets them out.

Most non-produced, non financial assets such as land and natural resources can’t be traded across borders.  All that can change is their ownership.  But there can be trade in non-produced assets like brand names, trademarks, logos, domain names and other marketing assets.  The IP onshoring to Ireland in recent years has included significant amounts of these.

In 2018, net acquisitions of non-produced assets exceeded €50 billion.  These acquisitions will have reduced financial net worth through either the reduction of financial assets to pay for them or, more likely, an increase in financial liabilities if debt is used to buy them.  In per capita terms, the amount is around €10,000 per person so goes someway to explaining the reduction in total economy net worth per capita shown for 2018 in the first chart.

There is a growing list of countries who provide figures for non-produced assets to Eurostat but it remains a minority.  Czechia and France provide the most comprehensive figures but all Germany, Estonia, Croatia, The Netherlands, Austria, Slovakia, Finland and Sweden now provide figures for the value of land. 

For produced assets Ireland has a fairly comprehensive figures for fixed assets (some suppression issues aside) but no figures for inventories or valuables.  Most countries provide figures for inventories to Eurostat but only a small minority do so for valuables.

The following table shows the gross amounts that give rise to the per capita figures in the first chart.

The financial figures can be counted in trillions.  At the end of 2020, financial assets on the national balance sheet summed to €9.0 trillion with liabilities of €9.7 billion.  This negative net financial worth was offset by the €1.1 trillion of non-financial assets included in the figures.  That gives the total economy net worth of €464.7 billion which translates to €93,400 in per capita terms.

As set out above the inclusion of other non-financial assets such as non-produced assets like land, natural resources and brands and other things like inventories or valuables would increase the net worth figure.  In most cases this would just be a change in level and the trend in net worth per capita would be largely the same.  As discussed above the inclusion of the non-produced assets purchased from abroad would impact both changes and levels.

The figures that are provided for produced fixed assets have a breakdown by type of asset.

The total stock of fixed assets has increased significantly in recent years but the largest contributors to this increase are the suppressed categories of IP and transport equipment.  When last broken out individually, for 2014, their combined value was €117 billion.  For 2020 the equivalent figure is €630 billion.  Turmoil in the aircraft leasing sector may have an impact of the 2022 figure.

We can do a sectoral breakdown of financial net worth:

This highlights that while the gross amounts for the financial sector are enormous, running into the trillions, the net amounts are relatively modest.  Non-financial corporations have built up a large negative net worth position in recent years.  This is linked to acquisition of assets such as IP and aircraft.

The government sector also has a significant negative position but did not lead to an equivalent increase in fixed assets as much of the debt was used to cover current spending. 

There has been a remarkable improvement in the net worth position of the household sector in recent years.  In the last two years shown in the above table the financial position of the household sector improved by €70 billion. 

Figures from the Central Bank suggest there was a further improvement of almost €50 billion in the financial position of the household sector in 2021.  This was achieved through a continued rise in deposits (+€16.2 billion) and also a large increase in life assurance and pension entitlements from private schemes (combined + €22.5 billion).  The contribution of debt reduction was relatively modest (€1.5 billion).

When housing assets are included (and the Central Bank include site value) the net position of the household sector is said to have improved by €140 billion in 2021, or €28,000 per capita.

The opening chart shows net worth per capita peaking in 2006 at €104,500.  The trend, and recent data from the Central Bank, suggest a new peak will be set in 2021. Hopefully it won’t go over a cliff this time.

To conclude, here are comparable figures for the EU15.  As discussed above some countries have more comprehensive figures available but there are presented here in a like-for-like basis.

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The next insight into Apple’s use of capital allowances

Apple revised its international structure in 2015.  Since then we have been tracking the impact of this via the annual publication of the consolidated accounts for the group of subsidiaries headed by Apple’s central international subsidiary, Apple Operations International (AOI).

• AOI’s 2018 Accounts: Some insight into Apple’s use of capital allowances
• AOI’s 2019 Accounts: Further insight into Apple’s use of capital allowances
• AOI’s 2020 Accounts: The latest insight in Apple’s use of capital allowances

There are details in the earlier posts that are not repeated here.  We will start with the consolidated income statement for the group.

AOI is at the head of an international group that comprises 80 other subsidiaries.  In total, the group an average number of employees of 52,563 in 2021 based in countries all around the world.  In essence, the above shows the performance of Apple outside the US, though we know Ireland is central to the financial outcomes generated.

In its annual report Apple Inc. sets out the split of its profit due to domestic (i.e. U.S.) operates and due to operations outside the U.S.  In its latest 10K filing with the SEC, the company said:

The foreign provision for income taxes is based on foreign pretax earnings of $68.7 billion, $38.1 billion and $44.3 billion in 2021, 2020 and 2019, respectively.

It can readily be seen that these amounts are close to the figures for “Income before provision for taxes” in the AOI group income statements in the table.  In line with the overall performance of Apple the outcomes for the AOI group improved in 2021.  Apple’s overall pre-tax income rose from $67 billion in 2020 to $109 billion in 2021.  As can be seen the pre-tax profit of the AOI group went from $34 billion to $68 billion over the same period.

The income statements also show a large “Provision for income taxes”.  This had been around $6 billion up to 2020 but jumped to $11 billion in 2021.  As discussed in the earlier posts, a company making a provision for income taxes is not the same as a company paying income taxes.  And again it is worth looking at the balance sheet to highlight this.

The line item of interest is that for “Deferred tax assets”.  These were $25.7 billion at the end of 2016 and had reduced to $7.8 billion at the end of 2021.  This indicates that a good share of the provision for income taxes on the income statement is not reducing cash on the balance sheet (via payments) but is depleting the deferred tax asset.  We will return to this but can make a quick stop with the cash-flow statement to confirm the point.

The supplemental item at the bottom confirms that the actual cash payments for income taxes have been significantly lower than the provision for income taxes.  For 2021, the provision for income taxes was $11.6 billion but actual payments made during the year were $4.4 billion.

Some of this could be due to timing differences if the actual payments are made after the year end but our interest is in the link between the provision for income taxes and deferred tax assets.  Some of the earlier posts go through the process that led to the generation of these deferred tax assets; here we will just focus on their evolution.

The above table corresponds to the deferred tax assets shown on the balance sheet.  And again, go from $25.7 billion at the end of 2016 to $7.8 billion at the end of 2021.  We are particularly interested in those that arise from intra-group transactions.

We know that a now Irish-resident entity in the AOI group purchased the license to exploit Apple’s IP in international markets and the upfront expense it incurred in acquiring this is eligible as a deduction, via capital allowances, until fully exhausted.

The accounting treatment means that the tax benefit of this deduction is put as a deferred tax asset on the balance sheet and is depleted year-by-year as it is used.  In recent years this reduction has been around $3.3 billion so is likely linked to annual profit of around $26 billion.

As can be seen the value of these deferred tax assets from intra-group transactions had fallen to $4.1 billion at the end of the 2021 financial year.  The limit on how much can be claimed in any single year means we are likely to see a further reduction of around $3.3 billion in 2022 and that the capital allowances will be fully exhausted in 2023.  It will be interesting to see what will happen then.

Irish Corporation Tax Payments

A related question is how much Irish Corporation Tax is paid.  However, this cannot be determined from the information presented in the consolidated accounts of the AOI group.  There will certainly have been some Irish tax in the $4.4 billion of cash tax payments made during the 2021 financial year but there is no way of knowing how much. 

The tax reconciliation in the accounts also points to the need to be cautious in drawing conclusions from the consolidated accounts.  This reconciles the provision for taxes with the tax charge that would apply is all pre-tax income was wholly and solely taxed at the 12.5 per cent.

The item worth looking at is the “Difference in effective tax rates on overseas earnings”.  Up to recently this had been a relatively small amount (at least in the context of the massive numbers in the accounts) but it jumped to $725 million in 2020 and then even more so to $2.3 billion in 2021.

As this table is taken from the consolidated accounts of a group of companies that operates in countries right around the world it is not clear what “overseas” means.  The 12.5 per cent rate is chosen presumably because the largest share of the profit of the group is subject to tax in Ireland (albeit offset by capital allowances).  So perhaps “overseas” means outside Ireland.  The accounts don’t indicate where AOI itself is resident but there were suggestions a number of years ago that it was resident in Jersey.

It is only a guess but if we take “overseas” to mean outside Ireland then it would indicate that a large share of the provision for income taxes, and also possibly the cash tax payments, are for non-Irish taxes.  We don’t know the amount of profit involved but if, say, the “effective tax rate on overseas earnings” shown in the above table for 2021 was 25 per cent then the amount of profit would be something approaching $20 billion.

Now, that 25 per cent is just an indicative number but illustrative of the rates and amount of profit needed to get the figure shown in the table.  In such a scenario $5 billion of the provision for income taxes would be due to the tax on overseas earnings.

So while the bottom line of the above table is a provision for income taxes of $11.6 billion for 2021, we know that around $3.3 billion was charged against a deferred tax asset on the balance sheet and some unknown amount, but likely running to several billion, was due to non-Irish taxes.

The likelihood is that there is a lot of Irish Corporation Tax being paid but we need more than what is shown in these accounts to be able to know how much that is.

From Apple’s 10K SEC filings we can see how much of its overall tax provision is due to non-US taxes.

A quick check of the total for foreign taxes in this table shows that it is close to the provision for income taxes of the AOI group.  The table from the 10K filing shows a big jump in current foreign taxes in 2021: from $3.1 billion to $9.4 billion.  The big jump in the AOI group accounts for “Difference in effective tax rates on overseas earnings” suggests that these non-US taxes were also non-Irish taxes (assuming “overseas” means outside Ireland). 

What we can say definitively is that the deferred tax assets of the AOI group arising from intra-group transactions are being depleted and at current usage are set to be exhausted during the 2023 financial year.  What happens then will be followed with interest and we may even get a post under the heading “The final insight into Apple’s use of capital allowances”!

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