Notes




Comments

Post a Comment

Popular posts from this blog

International Financial Services Centre

Image
The International Financial Services Centre ( IFSC ) is an area of central Dublin and part of the CBD established in the 1980s as an urban regeneration area and Special Economic Zone (SEZ) on the derelict state owned former port authority lands of the reclaimed North Wall and George's Dock areas of the Dublin Docklands. The term has now morphed into use as a metonym for the Irish financial services industry as well as being used as an address and still being classified as an SEZ. It officially began in 1987 as an SEZ on an 11-hectare docklands site in central Dublin, with EU approval to apply a 10% corporate tax rate for "designated financial services activities" on the site. Before the expiry of this EU approval in 2005, the Irish Government legislated to effectively have a national flat rate by reducing the overall Irish corporate tax rate from 32% to 12.5% which was introduced in 2003. An additional primary goal of the IFSC was to assist the urban renewal and developm...
Read more

Technology expansion

Image
The 2015 IFSC III phase saw the "financial" IFSC merge with the neighboring Grand Canal Dock and Dublin Docklands areas; comprising major offices of global technology multinationals including Google, Facebook, and Amazon. Since the 2015 expansion, the term "International Services Centre" (ISC) is sometimes used. Some of the biggest offices in the IFSC are the law firms (e.g. Matheson, A&L Goodbody, McCann Fitzgerald, and William Fry), and accounting firms (e.g. PwC, KPMG, Deloitte, and Ernst & Young), who advise both the financial multinationals and technology multinationals, operating in the Greater Dublin Area. The legal structures created by IFSC law and accounting firms for securitization (e.g. Section 110 SPVs, and QIAIFs), became important to the tax structuring of US technology firms in the IFSC. Such structures are part of a suite of base erosion and profit shifting (BEPS) tools that enable US technology firms to achieve an effective tax rate (ETR) o...
Read more

Tax haven concerns

Image
IFSC growth is closely related to concern regarding tax issues, and Ireland as a tax haven, estimated in 2018 by academics to be the world's largest tax haven. The role that the major IFSC accounting and IFSC law firms have played in creating Irish tax haven-type legal structures, including Double Irish, Single malt, and Capital allowances for intangible assets (CAIA) BEPS tools, as well as Section 110 SPV, QIAIF and ICAV zero-tax legal structures, has been chronicled. For example, PwC Ireland, one of the largest professional services firms in the IFSC, was identified in 2013 by Bloomberg as the "great architect" of the Double Irish arrangement, the largest known legal tax avoidance structure in history, responsible shielding over US$100 billion annually from taxation. In addition, Matheson, who state that they have the largest corporate tax group of all IFSC law firms, was identified in 2013 by the Wall Street Journal as the headquarters of 125 major US multi-nationals ...
Read more