tag:blogger.com,1999:blog-2826531655042170344.post1010755995038712537..comments2024-03-26T11:29:52.986+00:00Comments on Economic Incentives: What impact did the end of the ‘double irish’ have on Google Ireland Limited? NoneSeamushttp://www.blogger.com/profile/15679299530222667673noreply@blogger.comBlogger5125tag:blogger.com,1999:blog-2826531655042170344.post-35145666887788261142021-12-03T13:39:48.797+00:002021-12-03T13:39:48.797+00:00Being Irish incorporated had nothing to do with th...Being Irish incorporated had nothing to do with the "charge of royalties in the entire single market". The royalties were paid by a company in Ireland to a company in Bermuda. It is sales revenue that flows from other countries to Ireland.<br /><br />And now even though there is no longer an Irish-incorporated company in Bermuda the payment flows still exist. Sales revenues flows to Ireland and royalties are paid from Ireland. Stating that the Irish-incorporated company was the crux seems contradicted by the fact that the flows are same but now are being paid to a company in the United States. Suggests being Irish-incorporated was so crucial.Seamushttps://www.blogger.com/profile/15679299530222667673noreply@blogger.comtag:blogger.com,1999:blog-2826531655042170344.post-40116038603211063802021-12-03T01:14:28.721+00:002021-12-03T01:14:28.721+00:00It was in an Irish incorporated company and that i...It was in an Irish incorporated company and that is the crux of the whole issue. Being Irish incorporated meant that this company could charge royalties in the entire single market and they were allowable as expenses for tax purposes in other jurisdictions. If they had been charged by a true Bermudan company instead of a hybrid Irish Bermudan one, then they wouldn't have been allowable in other EU countries.<br /><br />Hard to tell if you are being deliberately disingenuous or if you just don't understand the subject very well.Anonhttps://www.blogger.com/profile/18395553062923481638noreply@blogger.comtag:blogger.com,1999:blog-2826531655042170344.post-19315783354417304862021-11-28T21:28:46.266+00:002021-11-28T21:28:46.266+00:00A very helpful analysis.
Strange that no one seem...A very helpful analysis.<br /><br />Strange that no one seems to care what happened after the end of the "double-Irish". Surely the IRS must be pleased to tax Google's royalties? Biden needs all the revenues he can muster, especially from Billionaires. MylesnaGhttps://www.blogger.com/profile/05603634900672928667noreply@blogger.comtag:blogger.com,1999:blog-2826531655042170344.post-62483899392177000412021-11-27T12:11:26.417+00:002021-11-27T12:11:26.417+00:00Yes, GILTI was introduced by the TCJA. The Act als...Yes, GILTI was introduced by the TCJA. The Act also introduced a deemed repatriation tax on pre-2018 foreign profits. The IP was never in Ireland so S291A would never have applied. A fuller discussion of the US changes was provided in this earlier piece<br /><br /><a href="http://economic-incentives.blogspot.com/2021/02/further-evidence-of-end-of-double-irish.html" rel="nofollow">http://economic-incentives.blogspot.com/2021/02/further-evidence-of-end-of-double-irish.html</a>Seamushttps://www.blogger.com/profile/15679299530222667673noreply@blogger.comtag:blogger.com,1999:blog-2826531655042170344.post-82233352490149274502021-11-25T16:30:29.093+00:002021-11-25T16:30:29.093+00:00You failed to mention that GILTI was only introduc...You failed to mention that GILTI was only introduced in 2017 which is a glaring omission. No doubt the result of the change would have been much greater had it happened prior to the US acting. With the IP residing in Ireland, we would have been taxing these profits at 12.5% prior to the introduction of the CAIA in 2009. Not sure what effective rate would have looked like post CAIA but to analyse the change now, long after the schemes usefulness has ended, is ignorant at best and malicious at worst.Anonhttps://www.blogger.com/profile/18395553062923481638noreply@blogger.com