Taxjustice.net
NARRATIVE REPORT ON IRELAND
Part 1: NarratIVE rEPOrt
How Ireland became an offshore financial centre
Overview and background
Ireland is ranked 37th in the 2015 Financial Secrecy index, based
Chart 1 - How Secretive? 40
on a very low secrecy score of 40, one of the lowest in our index,
combined with a weighting of just over two percent of the global market for offshore financial services. Yet despite Ireland's low
ranking we have chosen to probe it in detail because offshore financial centres are a political and economic phenomenon that
goes far beyond secrecy, and Ireland makes a remarkable case study.
Secrecy was never a central part of Ireland's ‘offshore' offering. Instead, its offshore financial centre is based on two other
key elements. The first, dating from 1956, is a regime of low corporate tax rates, loopholes and laxity designed to encourage
transnational businesses to relocate – often only on paper – to Ireland. The second big development has been the Dublin-based
International Financial Services Centre (IFSC), a Wild-West, deregulated financial zone set up in 1987 under the "voraciously
Exceptionally secretive
corrupt" Irish politician Charles Haughey: the IFSC has striven in particular to host risky international ‘shadow banking' activitya and it has posed – and continues to pose – grave threats to financial stability.
Chart 2 - How Big?
Ireland over half of the world's top 50 banks and half of the top 20 insurance companies; in July 2013 it nearly 14,000 funds (of which 6,000 were Irish-domiciled) administering an estimated €3.7 trillion: up from $840 billion a decade earlier. The Irish Stock Exchange hosts about a quarter of international bonds: Ireland is the domicile for around 50 percent of European ETF assets. In 2014 total IFSC foreign investment in liabilities was equivalent to around 15 times Ireland's Gross National Product (GNP;) as this report explains, many toxic developments in ‘subprime' markets that triggered the global financial crisis from 2008 can trace their lineage back to Ireland.
What is a tax haven or
Ireland hosts a of tax secrecy jurisdiction?
Ireland accounts for slightly over 2.3 per cent of the
haven deniers: as this report makes
global market for offshore financial services, making
clear, it is one of the world's most
it a large player compared with other secrecy
is a bit of a misnomer:
important tax havens or offshore these places aren't just
financial centres.
about tax. From political
The ranking is based on a combination of its
economy perspective, they
secrecy score and scale weighting.
Contrary to popular mythology,
offer escape routes to
Ireland's famous and sudden "Celtic
read more
financial players elsewhere
Tiger" economic boom from the early ("offshore"), helping them
1990s was driven not by Ireland's
avoid taxes, or disclosure,
corporate tax regime, but by other or financial regulation, or
Tax Justice Network 2015 - 23.9.2015
whatever other ‘burdens' of society they don't like. Read
If you have any feedback or comments on this
report, please contact us at [email protected]
factors, as this report explains. It was followed
In short, the tax haven strategy that began in
by a spectacular, debt-laden bust from 2008
1956 is now nearly six decades old -- and was
onwards, from which Ireland is only now starting
spectacularly unsuccessful for Ireland for most
to emerge. For proper context to this report, it
of that time. Note, too, that Ireland's famous
is important to explode the Celtic Tiger myth in
12.5 percent corporate tax rate was in fact a tax
more detail.
rate increase. What triggered the Celtic Tiger
era above all was Ireland's accession to the
The Celtic Tiger myth
EU single market in 1993 – plus several other factors. There are of course important nuances
The simple popular story is that Ireland used
in this basic story.
its 12.5 percent low corporate tax rate, and tax loopholes, to attract foreign multinational
On one level, this is a fairly straightforward tale
corporations, and built the so-called "Celtic
about corporate taxes, financial deregulation
Tiger" Irish economic boom on the back of
and their local economic impacts. But on
that, helping Ireland the single largest
another level this is an Irish version of a
location outside the US for the declared pre-
phenomenon we've encountered in tax haven
tax profits of U.S. firms. The Irish singer Bono
after secrecy jurisdiction: the state ‘captured'
echoed popular beliefs when he said that
by offshore financial services. Before exploring
Ireland's corporate tax system "brought our
this peculiar story of nepotism and hubris,
country the only prosperity we've known."b
however, it is worth providing more context for the Celtic Tiger.
The next graph helps illustrate why the popular story is quite wrong.
Chart 1: Ireland's GNP per capita, as a share of
European GNP per capita, 1955-2013
Source, Fools' Gold blog, March
10, 2015, and associated sources and links. Graph
created by John Christensen and Nicholas Shaxson.
what was most likely the boom's biggest driver: soaring property prices.
"it is difficult to avoid the conclusion that Irish economic performance has been the least impressive in Western Europe, perhaps in all of Europe, in the twentieth century ()."
The take-off that followed almost as soon as he had published those words was rocket-fired. During the spectacular upswing phase, most of what was written about this episode was uncritical, and often gushing: "an economy to be rather than examined," as one account put it. The describes the attitude:
The new government believed it had discovered a quicker-acting formula for wealth creation: tax cuts to stimulate consumption, property to replace manufacturing as the source of wealth, Dublin to become a tax haven for businesses seeking to avoid the more rigorous regimes of London and New York.
The fact that this looks so similar to our first
As mentioned, it was EU single market accession
graph in scale and timing is no coincidence: this
that was the big factor. But there were of course
was, once again, largely the result of Ireland's
several other crucial ingredients. One was the
accession to the EU single market, which
fact that Ireland had a skilled (and, crucially,
massively boosted housing finance, creating
English-speaking) and educated workforce –
an enormous new pool of available wholesale
many educated by the UK and other countries
funding with exchange-rate risks removede.
during earlier periods of mass Irish emigration – plus membership of the Euro currency from
Irish people only understood how ephemeral a
1999, not to mention a worldwide boom in
lot of this ‘growth' was when crisis hit.
global FDI flows at the time.
It is true that the tax offering did help attract
Inward FDI flows responded massively to all
large amounts of investment, particularly from
these factors: rising from 2.2% of GDP in 1990
U.S. multinationals – and European membership
to an astonishing 49.2% in 2000c. Boosting the
helped keep Ireland off tax haven blacklists that
Irish economy further, European agricultural
apply to classic tax havens such as Cayman and
spending on the country rose from just €500m
Bermuda; a broad network of with
in 1980 to €2bn annually on average from
other jurisdictions complement this.
1990-2010.d Yet the next graph that illustrates
but the story does not end there. The FDI
the European Economic Community (EEC)
benefits to Ireland may have been offset by
it suffered a setback when it was told that
the scale of the tax giveaway involved, and
these tax measures were discriminatory. The
these benefits also have accrued to a relatively
EEC allowed Ireland plenty of time to adapt,
small segment of Irish societyf. What is more,
however, and it responded by replacing the
Ireland has triggered ‘beggar my neighbour'
differential tax system with a single, across-the-
competition from other nations, meaning it has
board tax rate of 10 percent to apply without
to constantly offer new and larger subsidies to
discrimination to all industrial sectors.
mobile capital, just to keep upg.
Implementation of this single rate was delayed
It's also always important to stress that what
until 1981, however, and other sectors such
we've described in this section are simply the
as tourism, facing corporate tax rates of 40
costs and benefits to Ireland: the corporate
percent, began to lobby hard to obtain the same
tax haven strategy (and the financial centre
low tax rate. Finally, in 1997 it was announced
strategy, below) have transmitted tremendous
that Ireland would from 2003 introduce a 12.5
harms onto other countries, notably the U.S.
percent tax rate and expand its application to
which has seen Ireland help facilitate a massive
all trading companies, with non-trading income
transfer of wealth from ordinary taxpayers to
taxed at 25%. This happened over a decade
mostly wealthy shareholders.)
after the Celtic Tiger awoke.
The corporate tax haven strategy, in detail
Tax loopholes and transfer pricing
The Irish corporate tax haven strategy
Ireland's 12.5 percent corporation tax rate is
in 1956 with the Export Profits Tax Relief (EPTR) which completely exempted
Box: Apple, Facebook, Google and the Double
manufactured export goods from corporate
income and profits tax. This was pushed through by John Costello, the Irish Taoiseach (head of
The "Double Irish" scheme relied on two Irish-
incorporated companies: the first, taxable in Ireland,
government) in October 1956, who failed even
collects profits (say, from operations in Europe) but
to discuss the measure with other members of
wipes them out by paying royalties to a second Irish-
the government, and in the face of objections
incorporated company tax resident in another tax
from the Irish Revenue - relying instead (on
haven like Bermuda or Cayman, which won't tax them.
advice from his son-in law Alexis Fitzgerald and
In 2014 the Irish government, under international
other personal advisers. The ‘captured state,'
pressure, said it would phase out the Double Irish;
with its incestuous links among political and
new schemes are already in development.
economic insiders and absence of democratic debate, was evident from the outset.
A U.S. Senate investigation in 2013 found that the
U.S. technology firm Apple had used the Double Irish
The tax exemptions were expanded in the late
in what U.S. Senator Carl Levin called the "holy grail
1950s – not least with the Free Zone around
of tax avoidance. . magically, it's neither her nor
Shannon airport – the world's first Free Trade
there". These Irish-based entities were not taxable
zone – and the system really took off in the
anywhere, y no tax on the lion's
1970s when the Industrial Development
share of for Tax Justice
Authority (IDA) started aggressively marketing
in the U.S. that Apple would owe
Ireland's tax system internationally, under
nearly if it hadn't stashed its profits off
slogans such as ‘no tax' and ‘double your after-tax profits' (.)
An Irish subsidiary at the heart of Facebook's tax
affairs funneled profits of €1.75 billion in 2012 to a
While these antics attracted some investment
pre-tax loss of €626,000 by paying mighty ‘expenses'
and profit-shuffling to Ireland, the graph above
to another Irish Facebook subsidiary tax resident
shows that they failed to deliver economy-wide
in Cayman. Similarly, Google escaped $2 billion a
benefits And, as Ireland negotiated entry into
year in taxes using a "Double Irish" scheme via the
Netherlands and Bermuda.
well known, but less has been written about
Phil Burwell, said he had "no responsibility for
its role in providing prolific tax loopholes: a
the nominee directors or activities of the firms
far more important offering for many large
after they are incorporated."
The Irish Financial Services Centre (IFSC)
The key for multinationals is to make sure
The second main leg in Ireland's ‘offshore'
that the lion's share of profits can escape that
offer came with the birth of the Irish Financial
12.5 percent tax rate by being shifted to a tax
Services Centre.
haven (or nowhere – see the Box) where they get taxed lightly or not at all. Ireland makes this particularly easy to do, not only because
In the late 1970s a group of Irish officials, with
of the general laxity of its tax administration,
the help of Wall Street offshore lawyer
but more specifically via
sought to set up an offshore banking
tricks. Astonishingly, until 2010 Ireland had no
centre modelled on Bermuda. The Irish Central
meaningful transfer pricing legislation, allowing
Bank rejected it, saying that it "smacked of a
something of a Wild West free-for-all, which has
banana republic.)
since only been tightened up a little.h This lax regime produced famous wheezes such as the
Yet within a decade the concept had been
"Double Irish" tax scheme operated by the U.S.
revived, and pushed aggressively through by a
tech firms Facebook, Apple and Google (see
tiny group of insiders with very little democratic
The biggest early driver of the IFSC project was the (now billionaire) stockbroker , formerly of Citibank and
Pricewaterhousecoopers,
who first the idea to a few key individuals in a meeting in Kitty O'Shea's pub in Dublin. In 1985 he formally proposed the idea of a financial centre in Dublin to the government. Desmond's stockbroking firm part-financed the first full-scale feasibility study by PWC, and he also owned some
box) which have, as this graphic illustrates, led
of the original buildings that would become
to extremely low effective tax rates in Ireland
designated to the IFSC project. He then got
for US multinationalsi.
together with stockbroker Michael Buckley, later to become Chief Executive of Allied Irish
Shady shell companies
Bank, to the relevant section of the manifesto for the dominant political party,
Beyond these tax-structuring activities, Ireland
Fianna Fáil, during the 1987 election campaign,
– like many offshore jurisdictions – has also
with a promise of 7,500 full-time jobs within five
been happy to serve as an ask-no-questions
years. Fianna Fáil was led by Desmond's friend,
incorporation centre for shady businesses.
the politician Charles Haughey (see box), and
As the Irish Times in June 2013, one
although the document asserted that
Dublin-based company incorporation business
it was "not oriented in any way towards the
alone had set up some 2,000 shell companies,
creation of a tax haven," they all knew that the
some of which have been found to have been
truth would be the opposite.
involved in large-scale criminal activities around the world. The man behind the agency,
"‘Finance', in the current era,
Haughey was returned as Taoiseach (head of
is not just a sector of the
government) in March 1987, and within two months the government had chosen
economy; it is at the core of a
in Dublin to host the IFSC.
new social settlement in which
Padraig O'hUiginn, Haughey's super-fixer
the fabric of our society and
The IFSC project was bulldozered into place
economy has been reworked."
above all by a fixer named Padraig O'hUiginn, Haughey's right hand man. O'hUiginn
compete with nearby banking centres such
"tremendously strong personality" and
as Luxembourg and the Channel Islands,
"unique levels of say-so" in politics: Haughey
including a tax rate of 10 percent for licensed
reportedly considered him to be "as wise
companies. A raft of laws and rules, notable
as old sin himself." A leading employer said
for their laxity, were crafted to attract global
that O'hUiginn ‘could walk on water;' and when O'hUiginn spoke about "my 11 years working under three Taoisigh [Taoiseachs],"
Charles Haughey: corrupt offshore Taoiseach
businessman Tony O'Reilly that "three
The " Charles Haughey was
Taoisigh worked under O'hUiginn."
Irish Taoiseach (prime minister) for most of the
Allied Irish Bank's Buckley, O'hUiginn had
time between 1979 and 1992, roughly at the same
Haughey's authority to "persuade, bully .
time as Margaret Thatcher in the UK.
whatever needed to be done to get the other government departments on board." An Irish
Haughey owned a large yacht, racehorses, the
analyst, via email to TJN, said O'Huiginn's
private island of Inishvickillane, and a Georgian
main legacy was "to politicise the civil service
mansion with 250 acres near Dublin – yet few
so no-one critical of government policy was
could understand where this great wealth had
ever promoted. O'Huiginn did his master's
come from. Haughey's personal financial manager,
bidding (Haughey) and twisted all sorts of rules,
Des Traynor, was chairman ,
a Cayman bank which, along with various trusts and shell companies, was a part of an offshore
Padraic White, then head of the Industrial
web that constituted Haughey's personal finances.
An inquiry (the McCracken report) of 1997 into
democratic processes were shunted aside for
corrupt payments to Irish politicians came up
stonewalling from the Cayman Islands and was hampered by the fact that John Furze, the former
"Within the public service, new
MD of Ansbacher Deposits who faced questioning
initiatives tend to develop slowly.
over Haughey's finances, died in Cayman weeks
These are advanced, after much
before a key tribunal appeal in the case. The
consultation, and refined, usually
tribunal eventually found large-scale corrupt
by committees. So before a policy
and suspicious payments to and from Haughey
proposal finally emerges as government
running through secrecy jurisdictions including
policy, it must survive a high degree
Switzerland, Cayman, London and the Isle of Man.
of scrutiny via checks and balances.
Finlan O'Toole described Haughey as
. . In this instance, the composition of
"a self-procliamed patriot whose spiritual home
the IFSC committee made the vital
was in the Cayman Islands' and ‘[a] lover of his
difference. So when O'hUiginn [see box]
country who could treat it like a banana republic.
turned to any departmental secretary
. a man who called for sacrifices from his people
and gently enquired, ‘I presume this is
but was not prepared to sacrifice one tittle of the
possible,' there was no place to hide.j"
trimmings" [pp 127 and 131]
Tax incentives were created for the IFSC to
Haughey's pestilentially complex financial affairs are laid bare .
money management, foreign currency dealing,
In 2006 Depfa, which had a tiny sliver of just
equity and bond dealing, and insurance – and
€2.98 billion in equity bootstrapping nearly
the finance minister was given leeway to allow
€223 billion in gross assets, collapsed when
services "similar to or ancillary to those" – a very
its Irish subsidiary could not get short-term
broad net. The laws were fully in place within
funding. Later, the head of the German financial
just three months of the new government being
regulator Bafin said that the rescue of Hypo
formed, once again highlighting how normal
had "prevented a run on German banks and
processes of scrutiny had been steamrollered.
the collapse of the European finance system." A Bear Stearns holding company, Bear Stearns
The IFSC was marketed aggressively abroad
Ireland Ltd., was similarly leveraged, with a
with a showpiece seminar in the City of London
ratio of one dollar of equity underpinning $119
on St Patrick's Day, 1988. For financial sector
in gross assets. Even so, almost no analyses of
players Dublin had suddenly become, like
this and other episodes involving the likes of
– and in tune with the Irish corporate
Lehman Brothers, AIG and others, investigated
tax system – a Wild West of financial regulatory
the core role Dublin played in the problems that
indulgence. Almost immediately the world's
subsequently emerged.
banks descended on Ireland; by the end of that year fifty banks had applied for licences,
Ireland, it seems, had not been interested in
including Chase Manhattan and Citicorp.,
tackling or even investigating the dangers. The
Commerzbank, Dresdner Bank and ABN.
Irish financial regulator has been quoted as saying
Financial services activity in Ireland exploded,
that it had no responsibility for such entities: its
notwithstanding the somewhat
remit extended only to banks headquartered
taken by the Fine Gael government of
in Ireland. If the relevant documents were
1994-1997 towards what was seen as a Fianna
provided to the regulator by 3 p.m., Stewart
Fail project. Ireland, as one
a fund would be authorised by start of business the next day (a prospectus can run to
"began to see itself as an outpost of
200 or more pages; it can hardly be assessed
American (or Anglo-American) free-
between 3 pm and the close of business at 5
market values on the far edge of a
pm.!) Even years after the global financial crisis,
continent where various brands of
Ireland's regulator says that financial-vehicle
social democracy were still the political
corporations such as those that helped bring
Depfa down are not regulated: its role, it says, is to regulate firms but not specific financial
Perhaps the only detailed academic examination
products, and in 2013 that only
of Ireland's regulatory laxity comes from
two employees at the Central Bank oversee the
entire trillion-dollar industry. Again, this kind of
The IFSC, he reveals, formed a core element in
turning of a blind eye is a classic and deliberate
the toxic global "shadow banking" system that
led to the global financial crisis. For example, hedge funds would typically be listed in Dublin,
Another financial commentator
managed in London and domiciled in a classic
Ireland as "Germany's Offshore Tart," and noted
tax haven like the Cayman Islands.
to tap funds of ‘various shades of shadiness' from the former Soviet Union:
When the global financial crisis hit, many Dublin-listed structures collapsed. Germany's Sachsen
German banks used to fly their people
Bank, IKB, West LB and Hypo, for instance, all
from Germany to Ireland in order to do
required massive state aid after luxuriating in
deals that were not allowed in Germany.
Dublin's regulatory permissiveness. Hypo Bank
. This is known in the financial world
was bailed out with €102 billion in German
as jurisdictional arbitrage. You and I
state loans and guarantees after it took over
would call it cheating if we were feeling
Ireland-registered Depfa Bank based in Dublin.
charitable and lying if we weren't. . I
have spoken to such people. Usually I
officials often operating in secret, collaborating
can hear the sweat coming off them as
closely with global offshore financial sector
they ask how I got their number and
interests, and frequently leading to corrupt
where did I get my information.
and insider dealing at the expense of the rest of the population. These insiders successfully
According to an article in the Financial Times,
ring-fence the sector against local democratic politics, and intimidate tax authorities and
"The almost total absence of effective
regulators into giving them more or less free
banking regulation would be laughable
had it not been so serious. Irish business and the Fianna Fáil-led government
Jesse Drucker of Bloomberg News
enjoyed a long established, cosy
one of the key insiders:
camaraderie in which peer review or the effective implementation of basic
"Feargal O'Rourke, the scion of a
regulations was impossible. The result
political dynasty who heads the tax
was horrific: the bankruptcy of the
practice at PricewaterhouseCoopers in
entire Irish banking sector involving
Ireland. . He persuaded regulators
bad debts in excess of €70bn – one of
to eliminate a withholding tax on
the biggest financial busts in history."
profits that corporations move out of the country -- while separately advising
Tape recordings released by the Irish
his cousin who was finance minister.
Independent newspaper revealed that when
the government rescued Anglo Irish Bank
He was instrumental in creating an Irish
based on fictitious calculations of the bank's
tax-credit program that subsidizes the
bad debts, the executive said those calculations
research of companies like Intel Corp. -
had been "picked out of my arse;" Anglo Irish's
- another client. . O'Rourke sees no
Chief executive is said to have urged a colleague
conflict in his dual roles representing
to respond to anger in Germany, and elsewhere
private industry and advising the
at the damage spilling over with:
government on issues that benefit his clients.
‘ "Stick the fingers up!" To which his colleague responds with a spirited
In his book Ship of Fools, the Irish commentator
rendition of "Deutschland, Deutschland
Finlan O'Toole talks of "a lethal cocktail of global
über alles". Both men dissolved in
ideology and Irish habits" and, as one reviewer
The "captured state"
"All this has been accompanied by a
This history constantly provides reminders of
culture of corruption so shameless and
how Ireland shows all the symptoms of the
spectacular that it makes Dublin look
‘financially a phenomenon
like Kabul. The former prime minister
we've described in so many of our narrative
Charles Haughey stole €250,000 from a
reports on tax havens and secrecy jurisdictions.
fund set up to pay for a liver transplant
This involves nepotistic and often corrupt links
for one of his closest friends. . as
between business and politics and a deference
O'Toole points out, bribery, tax evasion
to offshore financial services and a society-wide
and false evidence under oath have not
consensus supporting the system.
simply gone unpunished; the very idea of penalising the culprits is viewed by
Since 1956, corporate tax and financial policies
the governing elite as unsporting or
have since 1956 been crafted with little
even unpatriotic."
or no democratic consultation by affected populations, and instead by small groups of
The willingness to brush dirt under the carpet
to support the financial sector, and an equating
indistinguishable.
of these policies with patriotism (sometimes
same deference to Big Finance and
known in Ireland as the ,)
multinational corporations prevails."
contributed to the remarkable regulatory laxity with massive impacts in other nations (as well
Or, as another observer more colourfully
as in Ireland itself) as global financial firms
sought an escape from financial regulation in
"is the Irish state's legal apparatus
whoring for the banks?"
The captured state was evident again at the
Another FT report in December 2013, entitled
height of the financial crisis. Jack Copley of
Irish pace of reform blamed on cronyism,
Warwick University describes one illustrative
highlights how the old ways of the past had
episode for the Fools' Gold blog: Experts
not been expunged, despite the scale of the
from Ireland's National Treasury Management
devastation wrought by the financial crisis,
Agency were brought to government offices on
the ensuing bailout, the public anger, and the
the night of the bailout, only to be
largest electoral mandate for change in the
history of Ireland. As Sinn Féin spokesman
while the Taoiseach, ministers and certain bank
Pearse Doherty put it, "The golden circle still
executives decided to issue a blanket guarantee
exists." The article quoted Donal Donovan of
of bank liabilities.m
the Irish Fiscal Advisory council as saying:
The problem appears to have continued almost
"The bailout treated the sick patient
unabated. A in the Financial Times
but didn't tackle the underlying issues
describes a meeting in 2011:
of political reform, a failure to listen to criticism and a reluctance to look
‘They met under the auspices of the
elsewhere for advice. . These factors
"Clearing House", a secretive group
were at the root cause of the financial
crisis and the previous Irish fiscal crisis
accountants and public servants formed
in the 1980s. Unless we think about
in 1987 to promote Dublin as a financial
this now it could happen again in 15
hub. . The participants thrashed out
years' time".
21 separate taxation and legal incentives sought by the financial industry at the meeting, which took place in room 308
read more
in the prime ministers' offices. .
The lobbying was done in secret behind
closed doors," says Nessa Childers,
an Irish member of the European
parliament, who got minutes of the
Fools' Gold Blog / Naked
meeting using freedom of information
Capitalism, March 10, 2015.
laws last year. "The bankers and hedge
fund industry got virtually everything
they asked for while the public got hit
Prof. Jim Stewart, Trinity College Dublin,
with a number of austerity measures".'
IIIS Discussion Paper No. 420, Jan 2013-
A September 2013 editorial by the Irish
political magazine highlights how
Tax Justice Focus, Vol.
the offshore financial consensus continued to
4 Number 2, 2008. Jim Stewart's article provides
pervade politics thereafter.
a much shorter summary of his subsequent paper.
"Never have two political parties
Eichengrw the single market boosted
paper, September 2011
property prices: "Claims on the Irish banking system
peaked at some 400 per cent of GDP . . this was
Progressive Tax Blog, Feb 23, 2011 (scroll
an exceptionally large, highly leveraged banking
system atop a small island. It grew out of the high
mobility of financial capital within the single market.
Sullivan, Forbes.com, Nov 6, 2013
It reflected [among other things] the freedom with
which Irish banks were permitted to establish
and acquire subsidiaries in other EU countries. It
2000. An uncritical yet informative chapter in
reflected the ease of accessing wholesale funding
the book The Making of the Celtic Tiger: the
given the perception that the exchange risk that
inside story of Ireland's boom economy, by Ray
would have otherwise been associated with making
MacSharry, Padraic White, 2000.
local-currency loans to Irish banks was absent in a
monetary union. It reflected the perception (more
accurately, the misperception) that bank failures, like sovereign defaults, had been rendered a thing of the past."
With thanks to Jim Stewart, Sheila Killian and
Tom McDonnell for their help with this article.
p13, Sheila Killian, submitted to Critical Perspectives in Accounting, 2006. Separatelythis ‘capture' may cause long-term trouble for Irish people. "As a country
grows more and more dependent on one source of revenue, be it mining or aid, the government
a The term "shadow banking" is attributed to the
becomes less and less dependent on, and so
U.S. financier Paul McCulley, who described it as
accountable to the people of the country. Instead,
"the whole alphabet soup of levered up non-bank
it focusses on meeting the needs of the sector or
investment conduits, vehicles, and structures." It
group which is essentially supporting its ability to
generally refers to banking activity that lies outside
remain in power. If this logic can also be applied
the purview of normal banking regulations.
to a relentless singleminded policy of using tax to
b Bono's comment came in response to criticism
attract FDI, the implications for Ireland are obvious
of him for calling for more tax-financed foreign aid
while his band U2 had been benefiting from various
g For example, Liechtenstein plans for
artificial tax-dodging arrangements.
a 12.5% across-the-board corporation tax rate,
c O'Hearn, D. (2000) Globalization, "New Tigers," and
explicitly to match Ireland's. The United Kingdom
the End of the Developmental State? The Case of the
has more recently competing tax
Celtic Tiger. Politics & Society. Vol. 28(1): 67-92 and
Kirby, P. (2010) Celtic Tiger in Distress: Explaining
h PwC the situation as "the absence of
the Weaknesses of the Irish Model.Second Edition.
local regulations and scrutiny prior to the 2010
Basingstoke: Palgrave Macmillan.
Finance Act." The changes in 2010 do not apply to
investors already in Ireland; and they are restricted
Jack Copley, Fools' Gold blog, May 5, 2015
to those profits that are subject to Ireland's 12.5
percent tax rate.
Fools' Gold Blog / Naked
i There has been plenty of myth-making in Ireland
Capitalism, March 2015, and associated sources on
about the corporate tax rate. Studies cited by the
Irish Times and others suggest that the effective tax
e (To be more precise, as Jack Copley of Warwick
rate is close to the headline 12.5 percent rate. But
University , this was a tale of two booms:
this is a fictional result based on a widely derided
first, a real FDI-based boom lasting from the early
result obtained by PWC, theoretical ‘standard firm
1990s to 2001; then a second property-based
with 60 employees which makes ceramic flower
one from 2001-2007.) The U.S. economist Barry
pots and has no exports: it is entirely inapplicable
to transnationals. See , Jim Stewart, IIIS Discussion Paper No. 442, Feb 2014. Though there are various ways to calculate effective tax rates, find rates of just 2.5-4.5 percent.
For some more examples of the Double Irish, see Jesse Drucker's reporting , or his looking at the drug Lexapro, which also used the Double Irish scheme. In 2014 it was announced that the Double Irish is being phased out: to see the kind of thing now replacing it see Leonid Bershidsky, Bloomberg, Oct 15, 2014j , by Ray MacSharry, Padraic White, 2000. k Our "" document explores this ‘capture' as a widespread phenomenon of tax havens and large financial centres.
l One reason for the regulators' laxity was the societal consensus that had built up, buttressed by active intimidation. As one player : "I remember once sitting in a meeting with the management of an Irish bank, who were chortling at the foolishness of the Irish Financial Regulator employee who had asked for details of all the mortgage loans they had made above 85% loan-to-value. Apparently they had called his boss and asked for the details of the warehouse that they were meant to send three lorries of paper files to. This sort of regulator intimidation — of course they could have sent a couple of CDs and I bet today they wish they had done — really did used to go on.)"m Jack Copley, Fools' Gold blog, May 5, 2015
Part 2: IrELaND'S SECrECY SCOrE
TRANSPARENCY OF BENEFICIAL OWNERSHIP – Ireland
Banking Secrecy: Does the jurisdiction have banking secrecy?
Ireland partly curtails banking secrecy
Trust and Foundations Register: Is there a public register of trusts/foundations, or are trusts/
foundations prevented?Ireland partly discloses or prevents trusts and private foundations
Recorded Company Ownership: Does the relevant authority obtain and keep updated details of
the beneficial ownership of companies?
Ireland - Secrecy Score
Ireland partly maintains company ownership details in official records
KEY ASPECTS OF CORPORATE TRANSPARENCY REGULATION – Ireland
Public Company Ownership: Does the relevant authority make details of ownership of companies
available on public record online for free, or for less than US$10/€10?Ireland partly requires company ownership details to be publicly available online
Public Company Accounts: Does the relevant authority require that company accounts are
made available for inspection by anyone for free, or for less than US$10/€10?Ireland requires company accounts to be available on public record only for a fee
Country-by-Country Reporting: Are all companies required to publish country-by-country
financial reports? Ireland partly requires public country-by-country financial reporting by some companies
EFFICIENCY OF TAX AND FINANCIAL REGULATION – Ireland
Fit for Information Exchange: Are resident paying agents required to report to the domestic tax
administration information on payments to non-residents?
partly requires resident paying agents to tell the domestic tax authorities about payments to
non-residents
Efficiency of Tax Administration: Does the tax administration use taxpayer identifiers for
analysing information efficiently, and is there a large taxpayer unit?
Ireland partly uses appropriate tools for efficiently analysing tax related information
Avoids Promoting Tax Evasion: Does the jurisdiction grant unilateral tax credits for foreign tax
payments?Ireland partly avoids promoting tax evasion via a tax credit system
Notes and Sources
Harmful Legal Vehicles: Does the jurisdiction allow cell companies and trusts with flee clauses?
Ireland partly allows harmful legal vehicles
The ranking is based on a combination of its secrecy score and scale weighting to see our full methodology).
INTERNATIONAL STANDARDS AND COOPERATION – Ireland
The secrecy score of 40 per cent for Ireland has been computed by assessing its performance on 15
Anti-Money Laundering: Does the jurisdiction comply with the FATF recommendations?
Key Financial Secrecy Indicators (KFSI), listed on the
Ireland partly complies with international anti-money laundering standards
left. Each KFSI is explained in more det
Automatic Information Exchange: Does the jurisdiction participate fully in multilateral Automatic
Green indicates full compliance on the relevant
Information Exchange via the Common Reporting Standard?
indicator, meaning least secrecy; red indicates non-
Ireland participates fully in Automatic Information Exchange
compliance (most secrecy); and yellow indicates partial compliance.
Bilateral Treaties: Does the jurisdiction have at least 53 bilateral treaties providing for information exchange upon request, or is it part of the European Council/OECD convention?
This paper draws on data sources including
regulatory reports, legislation, regulation and news
As of 31 May, 2015, Ireland had at least 53 bilateral tax information sharing agreements
available as of 31.12.2014 (with the exception of
complying with basic OECD requirements
KFSI 13 for which the cut-off date is 31.05.2015).
International Transparency Commitments: Has the jurisdiction ratified the five most relevant
Full data on Ireland is available here:
international treaties relating to financial transparency?
Ireland has ratified the five most relevant international treaties relating to financial transparency
All background data for all countries can be found on the Financial Secrecy Index website:
International Judicial Cooperation: Does the jurisdiction cooperate with other states on money
laundering and other criminal issues?Ireland cooperates with other states on money laundering and other criminal issues
Source: http://www.taxjustice.net/wp-content/uploads/2015/11/Ireland.pdf
The Extraction of Native Giardia lamblia Actin Through Differential Detergent Treatment Nicholas Barker Stoler Submitted in fulfillment of the Senior Thesis requirement in the Department of Biology, Georgetown University, Washington, D.C., May 2008 NICHOLAS B. STOLER The Extraction of Native Giardia lamblia Actin Through Differential Detergent
N o v e m b e r CONTENTS / SUMARIO 38th International Trophy for Quality / XXXVIII Trofeo Internacional a la Calidad Forty companies have been awarded with the International Trophy for Quality 2010. This Trophy for Quality has been created by Editorial OFICE through the Trade Leaders' Club and is