19/2/20: Facebook becomes another Ireland Inc's reforms test case

First the 'anti-American'  EU Commission's moved against a wonderful U.S. company washing tens of billions of tax free money through Ireland (see: https://www.reuters.com/article/us-eu-apple-stateaid/apple-says-14-billion-eu-tax-order-defies-reality-and-common-sense-idUSKBN1W1195) and now, the U.S. IRS ('anti-American' as they are) have moved against another wonderful U.S. company washing billions of tax free money through Ireland.

The latest case is, of course, the anti-American IRS suing Facebook over its shenanigans in Ireland: https://www.reuters.com/article/us-facebook-tax/facebook-faces-tax-court-trial-over-ireland-offshore-deal-idUSKBN20C2CQ. Per report: "The IRS argues that Facebook understated the value of the intellectual property it sold to an Irish subsidiary in 2010 while building out global operations, a move common among U.S. multinationals."

It is worth noting that this intellectual property redomiciling to Ireland has dramatically increased since the irish Government 'tax reforms' of 2014. Whilst the CSO does not fully account for such transfers in its GNI* measure, the gap between Irish GDP and GNI* has accelerated to historically new levels in recent years, as highlighted here: https://trueeconomics.blogspot.com/2020/02/9220-ireland-more-of-reformed-tax-haven.html.

The case is yet another hammer blow to Ireland's reputation in international economic policy circles and a testament that Ireland's famed compliance with the OECD BEPS rules is a fig leaf of decorum, to be stripped publicly by the EU and the U.S. (and probably other G20) authorities in years to come.

9/2/20: Ireland: More of a [reformed] Tax Haven than Ever Before?..

With the demise of the last Government and the uncertain waters of Irish politics stirred by the latest election results, let me take a quick glance at the Government's tenure in terms of perhaps the most important international trend that truly threatens to shake the core foundations of the Irish economy: the global drive to severely restrict corporate tax havens.

In Ireland, thanks to the CSO's hard labours, there is an explicit measure of the role played by the international tax avoiding corporations in the country economy. It is a very imperfect measure, in so far as it significantly underestimates the true extent of the tax arbitrage that Ireland is facilitating. But it is a robust measure, nonetheless, because it accounts for the lore egregious schemes run in capital investment segments of the corporate tax strategies.

The measure is the gap between the official Irish GDP and the CSO-computed modified Gross National Income, or GNI*. The larger the gap, the greater is the role of the tax shifting multinationals in the Irish national accounts. The larger the gap, the more bogus is the GDP as a measure of the true economic activity in Ireland. The larger the gap, the poorer is Ireland in real economic terms as opposed to the internationally-used GDP terms. You get the notion.

So here are some numbers, using CSO data:

When Fine Gael came to power in 2011, Irish GNI* (the more real measure of the economy) was 26.03 percent lower than the Irish GDP, in nominal terms. This, effectively, meant that tax shenanigans of the multinational corporations were de facto running at at least 26% of the total Irish economic activity.

Fine Gael proceeded to unleash and/or promise major tax reforms aimed at reducing these activities that (as 2014 Budget, released in October 2013 claimed, were harmful to Ireland's reputation internationally. The Government 'closed' the most notorious tax avoidance scheme, the Double Irish, in 2014, and introduced a major new 'innovation', known as the Knowledge Development Box (aka, replacement for the egregious Double Irish) in 2016. In September 2018, the Government published an ambitious Roadmap on Corporation Tax Reform (an aspirational document aiming to appease US and European critics of Ireland's tax avoidance platform).

So one would expect that the gap between Irish GNI* and GDP should fall in size, as Ireland was cautiously being brought into the 21st century by the FG government. Well, by the time the clocks chimed the end of 2018, Irish GNI* was 39.06 percent below the Irish GDP. The gap did not close, but instead blew up.

Over the tenure of FG in office, the gap rose more than 50 percent! Based on 2018 data (the latest we have so far), for every EUR1 in GDP that Irish national accounts claim to be our officially-declared income, whooping EUR0.391 is a mis-statement that only exists in the imaginary world of fake corporate accounts, engineered to squirrel that money from other countries tax authorities. Remember the caveat - this is an underestimate of the true extent of corporate tax shifting that flows through Ireland. But you have an idea. In 2011, the number was EUR0.260, in 2007, on the cusp of the Celtic Garfield's Demise, it was EUR0.1605 and in 2000-2003, the years of the Celtic Garfield's birth when Charlie McCreevy hiked public expenditure by a whooping 48 percent, it was averaging EUR0.1509.

Think about this, folks: McCreevy never waged a battle to get Irish tax system's reputation up in the eyes of the critically-minded foreigners and yet, his tenure's end was associated with the tax optimisation intensity in the Irish economy being whooping 24 percentage points below that of the 'reformist' Fine Gael.

This is mind-bending.

7/2/20: Someone, page Paul Krugman on this one: Irish Gross Value Added Data 3Q 2020

Remember that somewhat offensive, but also somewhat apt description of the Irish 2015 growth figures that Paul Krugman came up with? Well, le's call it the 'L-economics'. Now, the CSO recently published the latest figures (through 3Q 2019) on the gross value added in the Irish economy, as decomposed into 'Foreign-owned multinational enterprise dominated' sector and 'Other sectors excluding the foreign-owned multinational enterprise dominated sector'.  So here is a chart you do want to see, plotting the share of the 'Foreign-owned multinational enterprise dominated' sector of the total gross value added across all of the Irish economy:

Now, see that massive spike in 1Q 2014? Aha, that was Krugman's 'L-economics'. Back then, the share of the MNCs' [dominated sectors] in the Irish economy jumped from 2014 annual average of 26.4 percent to 2015 annual average of 38.36 percent. And then we thought, surely, things are going to calm down a bit at the Silicon Docks, right? Not quite. In 2018, the share averaged 42.4%. Boom! And in the first three quarters of 2019 it jumped to 44.1 percent. Double Boom!

Comically, or sarcastically, or may be... ah, neah... never mind. At the last 7 quarters growth rates, folks, by 2035, three quarters of the Irish economy will be... err... Krugmanited. So, OECD, G20 and the rest of the global tax justice worriers, there's nothing to see on the shores of the Liffey.

27/1/20: The Value of History and the Shifting Winds of Public Policy

My latest contribution to the Manning Financial for January 2020 is out: https://issuu.com/publicationire/docs/mf_january_2020?fr=sZTk2MDI2MTg4NA.

15/12/19: Under the Hood of Irish National Accounts: 3Q 2019 Data

CSO have released the latest (3Q 2019) data for the National Accounts. The headlines are covered in the release here: https://www.cso.ie/en/releasesandpublications/er/na/quarterlynationalaccountsquarter32019/ and are worth checking. There was a massive q/q increase in GNP (+8.9%) and a strong rise in GDP (+1.7%).

Official value added q/q growth figures were quite impressive too:

• Financial & Insurance Activities value added was +5.7 percent in volume, all of which, judging by the state of the Irish banks came probably from the IFSC and insurance premiums hikes
• Professional, Administrative & Support Services +5.1 percent (this sector is now heavily dominated by the multinationals)
• Public Administration, Education and Health sector lagged with a +1.5 percent 
• Arts & Entertainment +1.8 percent
• Construction grew by much more modest +1.3 percent 
• Industry (ex-Construction) fared worse at +1.1 percent 
• Information & Communication increased by 0.8 percent over the same period
• Meanwhile, more domestic-focused Agriculture recorded a decline of 3.2 percent 
• Distribution, Transport, Hotels & Restaurants posted a decline of 1.0 percent.

On the expenditure side of accounts:

• Personal Consumption Expenditure increased by 0.9 percent q/q
• Government expenditure increased 1.2 percent.

Not exactly the gap we want to see, especially during the expansionary cycle, but public consumption has been running below private consumption in level terms ever since the onset of the recovery.

With this in mind, here is what is not discussed in-depth in the CSO release. CSO reports a measure of economic activity that attempts to strip out some (but not all) of the more egregious effects of the tax optimising multinational enterprises' on our national accounts. The official name for it is 'Modified Domestic Demand', "an indicator of domestic demand that excludes the impact of trade in aircraft by aircraft leasing companies and trade in R&D service imports of intellectual property". Alas, the figures do include intangibles inflows, especially IP on-shoring, income from domiciled intangible assets, and transfer pricing activities. Appreciating CSO's difficulties, it is virtually impossible to make a judgement as to what of these three components is real (in so far as it may be actually physically material to Irish enterprises and MNCs trading from here) and what relates to pure tax optimisation.

With liberty not permitted to CSO, let's take the two categories out of the aggregate modified demand figures.

So, this good news first: Modified Total Domestic Demand is growing and this growth (y/y) is improving since hitting the recovery period low in 3Q 2018. 

Bad news: growth in modified domestic demand remains extremely volatile - a feature of the Irish economy since mid-2014 when the first big splashes of the Leprechaun Economics started manifesting themselves (also see last chart below).

Not great news, again, is that domestic growth is not associated with increases in investment (first chart above, blue line). 

More good news: in levels terms, adjusting for inflation, Ireland's Modified Domestic Demand has been running well-above pre-crisis period peak average levels for quite some time (chart below). Even better news, it appears that much of the recent support for growth in demand has been genuinely domestic.

Next chart shows y/y growth rates in the headline Modified Total Domestic Demand as reported by the CSO (blue line) and the same, less transfer pricing, stocks flows and IP flows (grey line). 

Starting with mid-2014, there is a massive variation in growth rates between the domestic economy growth rates as reported by the CSO and the same, adjusting for MNCs-dominated IP and transfer pricing flows, as well as one-off effects of changes in stocks (inventories). There is also tremendous volatility in the MNCs-led activities overall. Historically, standard deviation in the y/y growth rates in official modified domestic demand is 5.68, and for the period from 3Q 2014 this is running at 5.09. For modified demand ex-transfer pricing, IP and stocks flows, the same numbers are 6.12 and 1.62. 

Overall, growth data for Ireland has been quite misleading in terms of capturing the actual tangible activities on the ground in prior years. But since mid-2014, we have entered an entirely new dimension of accounting shenanigans by the multinationals. Much of this is driven by two factors:

1. Changes in tax optimisation strategies driven by the international reforms to taxation regimes and the resulting push by the Irish authorities to alter the more egregious loopholes of the past by replacing them with new (IP-related and intangible capital-favouring) regime; and
2. Changes in the ays in which MNCs prioritise specific investment inflows into Ireland, namely the drive by the MNCs to artificially or superficially increase tangible footprint in the Irish economy (investment in buildings, facilities and on-shored employment) to provide cover for more tax-driven FDI.

Time will tell if these changes will lead to more or less actual growth in the real economy, but it is notable that the likes of the IMF have recently focused their efforts at detecting tax optimising activities at national levels away from income flows (OECD approach to tax reforms) to FDI stocks and firm-level capital activities. By these (IMF's) metrics, Ireland has now been formally identified as a corporate tax haven. How soon before the OECD notices?..

9/1/19: Corporate tax inversions and shareholder wealth

Our new paper "U.S. Tax Inversions and Shareholder Wealth" has been accepted for publication in the International Review of Financial Analysis:

The paper abstract:
"We examine a sample of corporate inversions from 1993-2015 by firms active in the U.S. markets and find that shareholders experience positive abnormal returns in the short-run. In the long-run, inversions have a deleterious effect on shareholder wealth. The form of the inversion and country-pair differences in geographic distance, economic development and corporate governance standards are determinants of shareholder wealth. Furthermore, we find evidence of a negative and non-linear relation between CEO total return and long-run shareholder returns."

14/5/18: Irish Tax Avoidance Machine and the Balance of Payments

One blog post and one paper tackling one of the greater mysteries of the Irish National Accounts, the Balance of Payments, peeling the layers of tax avoidance onion:

• Tax Avoidance and the Irish Balance of Payments paper: https://www.cfr.org/blog/tax-avoidance-and-irish-balance-payments?utm_medium=social_share&utm_source=tw;
• The 2017 Balance of Payments post: http://economic-incentives.blogspot.com/2018/04/the-2017-balance-of-payments.html.

Both worth digesting.

25/2/2018: Tax Havens and Financial Secrecy ca 2018

The notion of what defines a tax haven is a complex one and does not easily lend itself to a precise definition. This presents numerous problems. As a personal example is an academic paper that I am currently working on with three other co-authors in which we had to use several different definitions of tax havens, primarily because the official (OECD) designations were so deeply politicized as to exclude a wide range of countries.

Tax Justice Network this week published its Financial Secrecy Index (https://www.financialsecrecyindex.com/). The Index is based on 20 tax policy-specific indicators, which are described here (https://www.financialsecrecyindex.com/introduction/method-and-concepts) and in broad terms provides a view of just how open the country is to facilitating tax avoidance or tax evasion through its financial laws, regulations and systems. The 20 indicators are:

• Banking secrecy
• Wealth Ownership disclosures, covering: existence of a public Trust and Foundations Register, Recording of Company Ownership disclosures, and Other Wealth Ownership
• Limited Partnership Transparency, Public Company Ownership, Public Company Accounts
• Country-by-Country Reporting, and Corporate Tax Disclosure, Legal Entity Identifier, and Tax Administration Capacity
• Consistent Personal Income Tax
• Does the jurisdiction facilitate tax avoidance and encourage tax competition with its treatment of capital income in local income tax law? Is there tax court secrecy, and are there harmful tax structures, e.g. bearer shares; use of large banknotes, existence of trusts with flee clauses, etc
• Public Statistics disclosures about international financial, trade, investment and tax position
• Anti - Money Laundering regime 
• Automatic Information Exchange, Bilateral Treaties, and International Legal Cooperation

Using the methodology described in the above link, the Tax Justice Network arrive at the country rankings in terms of how open the country system is to facilitation of tax avoidance and evasion, including through provision of financial secrecy and non-disclosure facilities that help international companies and investors avoid tax payments in their jurisdictions of origin.

The results are surprising, because they stand in a stark contrast to politically sanitized version of tax avoidance lists published by the likes of the toothless and politically controlled OECD:

Here's the top shocker: the U.S. - a country that routinely bullies other jurisdictions when it comes to extracting tax data that serves the American own purposes is number two most active tax avoidance facilitation countries in the world.  Germany, another stalwart of anti-tax avoidance rhetoric and co-sponsor of the OECD's BEPS anti-tax avoidance process alongside the U.S. is ranked number 7. Japan is number 13. Canada is number 21. And so on.

Another surprise, Ireland - previously ranked 37th in 2015 Index, with a secrecy score of 40 (see https://www.financialsecrecyindex.com/Archive2015/CountryReports/Ireland.pdf), the country is now ranked 26th, with a secrecy score of 51 (this year's country report here: https://www.financialsecrecyindex.com/PDF/Ireland.pdf). In other words, things are not quite improving for Ireland.

A third surprise is Lichtenstein. This country has been commonly accused of being a major secrecy tax haven for financial flows, quite often, without any serious consideration of the more recent reforms in the country's financial services sector. Yet, Lichtenstein ranks lowly 46th in the index, just below Norway. IN the same vein, Cyprus - that has been effectively labeled a dirty money Island for Russian mobsters during 2011 financial restructuring episode - ranks reasonably low at 24th place, well better than Germany - a country from which these accusations originated.

These, and other considerations, arising from the Index results should remind us of the complexity involved in assessing the extent of financial and tax systems facilitation of illicit and ethically questionable activities. Tax havens come in all forms and shapes, some benign, others damaging to the socio-economic environments, many having an adverse impact only in the long run.

It is quite easy for the media to label a jurisdiction a safe haven for crime. It is much harder to establish an empirical basis to either support or reject such a label.

5/1/17: Gwan Ya Beaut... Irish PMIs ≠ Irish GDP

Some years ago, I have shown that Irish measures of economic activity - when collected at sectoral levels - have virtually nothing in common with Irish GDP and GNP. Given recent revisions to economic growth and the National Accounts, including the absurd levels of notional GDP and GNP growth recorded in 2015 and in parts of 2016, it is worth to revisit the same issue.

So here is the data: the best advanced indicator data on Irish economic activity that we have is the set of Purchasing Managers Indices (PMIs) released by Markit for three key sectors of the economy: Construction, Manufacturing and Services. Markit are doing pretty much an honest job surveying companies to determine if they are experiencing uptick or decline in their activities. And they are doing this every month. Yes, there are issues with data quality due to what appears to be a strong pro-MNCs bias in the surveys. And yes, Markit are refusing to fully investigate the matter and to test data formally for such biases. And yes, Markit are still not willing to share with me their data, including the actual final data set of PMIs (I have to collect these manually, every month).

But, for all the above problems, Markit is the only source of leading economic indicators for Ireland.

So next is the question: do rates of growth signalled by PMIs actually relate to the rates of growth recorded in the economy (GDP and GNP)?

Let’s take a look, using CSO’s official National Accounts data.

The above shows whatever is happening in Manufacturing. Nope, growth rates signalled by PMIs are not correlated with growth rates in GDP or GNP.  Changes in Manufacturing PMI signals account for only 9.3% of variation in GNP and 6.4% variation in GDP. You wouldn’t be asking Manufacturing sector for its view if you wanted to gauge Irish aggregate economy. 

The above shows what is happening in Services. Again, growth rates signalled by Services PMIs are not correlated with growth rates in GDP or GNP.  Changes in Services PMI signals account for only 12.6% of variation in GNP and just under 8% variation in GDP. You wouldn’t be asking Services sector for its view if you wanted to gauge Irish aggregate economy either.

Why are both sectors signals come out utterly useless when it comes to signalling growth in either GDP or GNP? We have no idea. But my speculative view is that in reality, even large MNCs can’t organically establish their own ‘contributions’ to Irish GDP because whilst purchasing managers and related executives on operations side might know what their divisions are doing and how much more or less business they are handling, the same managers have no idea what value in the end will be attached to their divisions work by the finance lads on the Mother Ship. In other words, real operations managers have no clue how much their companies are booking in revenues or profits because these revenues and profits have only tangential connection of Irish operations. Tax arbitrage is such a naughty thingy, you see, when it comes to collecting data.

Not that Markit (or a vast array of Irish stuff brokers so keen on using its data to ‘interpret’ ‘buy everything’ signals for Irish assets) mind… Gwan, ya beaut... buy some stocks, will ya?

7/12/16: Bloomberg Blows the Cover on Apple's Irish Tax Dodge, Again

So you know the $13 billion that Apple, allegedly, owes Ireland?.. It really never did owe Ireland much. Instead, it owes the money to taxpayers outside Ireland - in countries where actual business activities took place and in the U.S., where Apple tax avoidance scheme starts, ends and start again. Here's how Bloomberg explains it: https://www.bloomberg.com/graphics/2016-apple-profits/

Oh, yeah, you are reading it right: "a popular corporate tax haven"... that'll be Ireland (per Bloomberg). expect loud protests from Dublin to Bloomberg offices and, potentially, a re-drawing of the scheme to alter the wording...

But you do get an idea: 10 years, at, say $600 million payments, that'll be almost half the $13 billion 'owed to Ireland' that is really U.S. taxpayers cash...

22/10/16: Irish 12.5% Tax Rate and Someone's Loose Lips

It has been some time since I commented here on the matters relating to Irish corporate taxation. For a number of reasons not worth covering. But one piece of rhetoric in the post-AppleTax ruling by the EU Commission has caught my mind today: the statement from the Taoiseach Enda Kenny on the issue of 'Loose Lips Sink Ships'.

Here's what happened: as reported in the Irish Independent, the Taoiseach "warned that "loose talk" about taxation in Ireland was potentially damaging in the face of the Brexit threat. "Ireland will obviously debate these things constructively but to be clear about it, our 12.5pc corporate tax rate is not up for grabs... It's always been 12-and-a-half and it will remain so."" The statement was prompted by the rumours (err... reports) "the European Commission has not ruled out examining 300 more of Ireland's tax rulings."

Mr Kenny said that "The commission have never stated that there are other impending state aid cases against Ireland and to suggest otherwise is mischievous, is misleading, and is wrong... And that type of loose talk is potentially very damaging to our country. It does impact upon companies looking - particularly given the Brexit situation - as to where they might want to invest."

So here's the problem, Mr. Kenny: no one is seriously suggesting that the problem with Irish corporate taxation is 12.5% headline rate. I have not seen any reasonably informed source commenting on this. The problem - as as subject of investigations by the EU Commission in the recent past - is the granting of preferential loopholes that went well beyond the 12.5% rate.

So what grave 'threat' to Ireland's tax regime is Mr. Kenny addressing by setting up a straw man argument about 12.5% rate 'rumours'? Answering that question would likely expose whose lips are loose on the matter. My suspicion is that Mr. Kenny deliberately creates confusion between the discussion of the headline rate (which is not happening) and the discussion of the loopholes (which is probably on-going, because (a) things might not have stopped with Apple; and (b) global tax reforms - e.g. BEPS-initiated process - are still rolling out. If so, then it is Taoiseach's lips that might be doing Ireland's 12.5% headline rate some damage.

Personally, I believe Ireland's 12.5% corporate tax rate is just fine. And I also believe that special, individual company arrangements on any tax matters are not fine. I also believe that Ireland should phase the latter out in a transparent fashion, instead of creating another maze of non-transparent and gamable by the larger corporation 'knowledge development box' incentives. Incidentally, tax personalization for Irish entities continues, it appears, with the publication of the Finance Bill this week, where tax procedures for Section 110 companies valuation of inter-company loans was left largely a matter for individual arrangements. BEPS will take care of the rest, or it might not, but that would no longer be a matter of Ireland's failure and it won't challenge our 12.5% tax rate.

21/9/16: Apple Tax Case: Not the Rate, the Loopholes

My column for the Village covering the Apple Tax fiasco: http://villagemagazine.ie/index.php/2016/09/not-the-rate-the-loopholes/

As it says on the 'tin' - the problem with Apple Tax is not the rate of corporate taxation set in law in Ireland (the 12.5% 'red line' rate), and not tax competition, nor the benign nature of tax exemptions that Ireland bestows on all companies, including the MNCs. The problem is that these competitive aspects of the Irish regime are simply not enough for the likes of Apple, which pursued and obtained access to exemptions that any ordinary company operating in Ireland cannot avail of.

Hence, the red herring of the arguments that the EU Competition ruling is an attack on Irish tax rate. It is, instead, a challenge to the asymmetric preferences granted in the past (and still in use during the ongoing phase-out period) to a handful of MNCs over and above domestic companies. Lest we forget, for decades, Irish State had no qualms operating an openly discriminatory taxation regime that treated foreign investment-backed companies differently from domestic companies. Lest we omit considering the present, Irish State still has no qualms taxing human capital of its residents at rates far in excess of those applying to physical and financial capital. Lest we fail to think about it, Irish State has no qualms asymmetrically allocating the burden of the crisis to Irish people over and above our banks, foreign investors, foreign bondholders and vulture funds.

I am one of the most vocal advocates of low (benign) taxation, flat tax, competitive regulatory regimes (coupled with robust enforcement) and other means for improving the functioning of the private markets. Always been one and remain. I support real investment in the economy, both foreign and domestic and believe in a level playing field for entrepreneurs and enterprises, alike. But, folks, the debate around Apple Tax is not about 12.5% tax rate and Ireland's tax autonomy, but about asymmetric nature of privilege.

29/7/16: Tax Regime, Apple, Fraud?

We have finally arrived: a Nobel Prize winner, former Chief Economist and Senior Vice-President of the World Bank (1997-2000) on Bloomberg, calling Apple's use of the Irish Tax Regime 'a fraud': http://www.bloomberg.com/news/articles/2016-07-28/stiglitz-calls-apple-s-profit-reporting-in-ireland-a-fraud?utm_content=business&utm_campaign=socialflow-organic&utm_source=twitter&utm_medium=social&cmpid%253D=socialflow-twitter-business.

This gotta be doing marvels to our reputation as a place for doing business and for trading into Europe and the U.S.

The same as Facebook's newest troubles: http://www.irishtimes.com/business/technology/facebook-tax-bill-over-ireland-operation-could-cost-5-billion-1.2738677.

But do remember, officially, Ireland is not a tax haven, nor is there, officially, anything questionable going on anywhere here. Just 26.3 percent growth in GDP per annum, and booming corporate tax revenues that the Minister for Finance can't explain.

2/2/16: MNC Ireland: A new Documentary

A new and well-worth watching documentary on the power of multinational companies in Ireland and Ireland's status as a corporate tax haven is available here: https://vimeo.com/137175562.

Note: Strangely enough, the documentary cites me as a Chairman of the IRBA (which I was at the time). It is worth repeating again that I never speak on behalf of any organisation I am involved with and the IRBA never had a corporate opinion on any policy-related issues. I only express my own personal views.

26/11/15: On a long enough time line: Irish corporate inversions

Recently, I covered the Pfizer-Allergan ‘merger’ just as Irish media navel gazed into the usual ‘jobs for Ireland’ slumber.  [You can trace much of it from here: http://trueeconomics.blogspot.ie/2015/11/201115-inversion-debate-isnt-over.html]

Now, few links that catch up with my analysis:

1. Irish Times reported that the Exchequer may gain up to EUR620m in Pfizer’s Allergan deal, annually. Key quote: “Last year, Pfizer paid an effective tax rate of 26.5 per cent as a US company. Post-merger, it expects to pay between 17 and 18 per cent across the group. In Ireland, it will pay our 12.5 per cent tax rate on any international income routed through the new Dublin operation.” Err, Irish Times, no. Pfizer will be paying lower effective rate than 12.5% because it will be able to avail of the famous/infamous OECD-allegedly-compliant ‘Knowledge Development Box’. How much lower? Ah, who knows. http://www.irishtimes.com/business/health-pharma/state-may-gain-up-to-620m-in-pfizer-s-allergan-deal-1.2441324
2. Bloomberg covers the same deal with a heading: “Pfizer's Viagra Tax Dollars Head to Dublin as U.S. Loses Again”. A bit of a miss, as Ireland already milks Viagra fortunes, though with the new ‘investment’ that will most likely increase. http://www.bloomberg.com/news/articles/2015-11-23/pfizer-s-viagra-tax-dollars-head-to-dublin-as-u-s-loses-again. Key quote: ““We are not pushing for inversions,” Irish Finance Minister Michael Noonan told reporters in Brussels on Monday, referring to the controversial transaction meant to cut corporate tax rates. The agency charged with winning investment for Ireland “never promotes inversions. It’s a decision for the two companies.” While Noonan said Allergan and Pfizer were plainly merging for “tax advantages,” the government has no problem with the deal as both companies had “substantial” operations in Ireland.” You have to be laughing… the same defence [we are not doing anything, all their fault] has been used in the past by Swiss and other tax havens to justify the arrival of tax-‘optimising’ money into the banks vaults. Now, it is Ireland’s turn. But for comical relief, we have this: “Patrick Coveney, chief executive of Greencore Group Plc, the Irish food company that’s the biggest sandwich maker in the U.K., told state-owned RTE Radio in Dublin on Tuesday that Pfizer’s proposed deal builds on its and Allergan’s presence in Ireland.” Yes, sandwich maker knows a thing or two about pharma and biotech. Next up: newsagent comments on new nuclear power plant design in the UK…
3. Not to be left behind, U.S. politicians are jumping on a carbon copy of the bandwagon too scared to actually join the bandwagon itself. Per Zerohedge: http://www.zerohedge.com/news/2015-11-23/hillary-slams-unfair-tax-inversions-after-sanders-calls-pfizerallergan-deal-disaster “Hillary Slams "Unfair" Tax Inversions After Sanders Calls Pfizer/Allergan Deal "Disaster For Americans”” Apparently, following in the footsteps of the completely out-of-touch Bernie Sanders, Hillary Clinton “firmly believes businesses should get ahead by building a stronger economy here at home, rather than using tax loopholes to shift earnings overseas, or to move abroad to escape paying their fair share.” Hillary went on to do what politicians do best: promise to do something. “In the weeks ahead [no idea when] I will propose specific steps to prevent these kind of transactions… I urge Congress to act immediately [pretty definitive timeframe when urging other to do something though] to make sure the biggest corporations pay their fair share, and regulators also should look hard at stronger actions they can take to stop companies from shifting earnings overseas.” So in basic term, Hillary has nothing to say other than that she has to say something. That’s novel.

All of this would be gas were it not serious. Despite Irish Government promises to curb ‘harmful’ tax practices, despite our vocal ‘compliance’ with the spirit of the OECD ‘reforms’, Ireland remains a premier destination for tax inversions from the U.S. Worse, everyone now knows this, and no one is doing anything about it. Worse, yet, everyone is next going to be aware of the simple fact that no one is doing anything about it.

On a long enough timeline, things will be easier in the short run as Irish Exchequer milks the rest of the world for tax optimising commissions. In the long run… well, we might have to start looking into how we will pay all these future pensions when the penny finally does drop in Washington and Berlin…

6/11/15: Allergan & Pfizer: More Happiness for OECD Tax Reformists

On foot of couple previous posts relating to Ireland-bound pharma inversions, here is an interesting link to the Bloomberg coverage of the Allergen shenanigans: http://www.bloomberg.com/news/articles/2015-11-02/a-pharmacist-s-dirty-socks-are-key-to-cutting-pfizer-tax-bill

With a nice chart to accompany:

Couple of links to my previous posts on the topic, covering

• Allergan-Pfizer merger: http://trueeconomics.blogspot.ie/2015/10/301015-none-of-them-harmful-tax.html
• Grifols of Spain re-domiciling accounting and other activities to Ireland: http://trueeconomics.blogspot.ie/2015/10/251015-grifols-and-ghosts-of-oecd.html and http://trueeconomics.blogspot.ie/2015/11/51115-grifols-at-last-in-irish-media.html

“We love your tax compliance theories, OECD!” Signed: Enda.

5/11/15: Grifols: At Last in Irish Media Spotlight

Two weeks ago I wrote about the tax-linked Spanish pharma Grifols move to Ireland (see link here) at the time when all Irish media was gushing on about jobs and investment, forgetting - conveniently and patently - the pesky issue of Why did a Spanish company decided all of a sudden to relocate major operations and international billing into Ireland?

Well, good to know that with a good week-and-a-half delay, the Irish Times woke up to the problem, covering it (albeit with usual 'diplomatic' caveats) here: http://www.irishtimes.com/business/economy/grifols-move-to-ireland-hits-tax-and-political-buttons-1.2415243.

One important aspect indirectly highlighted by the Irish Times article on the matter is the problem we are having with 'Brand Ireland' - the brand that is now visible across Europe and the U.S., as well as Australia and Canada as being linked with 'beggar thy neighbour' economics.

This strategy for growth is behind our 'stellar out-performance' on fiscal side, as another Irish Times article highlighted here: http://www.irishtimes.com/business/economy/tax-surge-from-multinationals-not-a-one-off-1.2416002. Stay tuned, as I will be covering the matter of 'sustainability' of our revenue and growth side in light of tax inversions and tax-fuelled FDI inflows later this month.

Note: about that 'beggar thy neighbour' economic development model: here is a note highlighting effects of Irish tax policies on the UK current account: http://uk.mobile.reuters.com/article/idUKKCN0SS00320151103?irpc=932. I disagree with the view that the distortion of national accounts aggregates has little effect on the real economy in the UK. In my opinion, it erodes tax base in the UK and transfers the benefits of MNCs activity accruing to Ireland into cost to British taxpayers. Someone pays for our gains, because tax is a zero-sum, non-value-additive activity.

4/8/15: Of Corporate Stash and Irish Cash

There are two things to notice in this Bloomberg chart:

Source: http://www.bloombergview.com/quicktake/profit-shifting-avoid-tax

First the obvious one: Our Not-a-Tax-Haven Ireland is in the company of Bermuda, Lux and Switzerland, alongside the equally Not-a-Tax-Haven Netherlands (that Double-Dutch Sandwich is an all-transparent arrangement to attract companies to Dutch quality workforce, only second to the best-in-class workforce of Ireland). That is trivial stuff, though.

Second (less trivial) is the quantum of profits domiciled in the likes of Ireland. It has been large and rising. And thus, if begs a question: What happens to Irish 'economic growth' when these profits are repatriated either for investment purposes abroad (e.g. in Asia Pacific or elsewhere) or on foot of any future tax amnesty in the US or both?

Answers to that question should be mailed to every Irish Minister so keen on confusing MNCs profits and Irish economic miracles.

27/5/15: CCTB is Baaaack...

It's Happy Hour again in Brussels, as the EU is reviving its plans for tax harmonisation across the continent.

At stake, the EU proposal for CCCTB, or Common Consolidated Corporate Tax Base, which would set the first precedent for tax harmonisation, outside Vat. As reported in the media, the plans appears to have support from the EU Commission (predictably), France (predictably) and Germany 9again, predictably). UK (predictably) is opposed: http://www.cityam.com/216514/uk-brushes-aside-german-tax-plan.

Today, the EU officials are discussing how to tackle tax avoidance and create a system of “fair, transparent and growth friendly” corporation taxation with discussion expected to “feed into” an announcement on corporation tax in June.

Key article on this is here: https://global.handelsblatt.com/edition/183/ressort/finance/article/a-tax-collision-course.

25/3/15: As Bogus Is, Bogus Does... IMF on Irish MNCs-led Growth

The IMF has published its Article IV consultation paper for Ireland and I will be blogging more on this later today. For now the top-level issue that I have been covering for some time now and that has been at the crux of the problems with irish economic 'growth' data: the role of MNCs.

My most recent post on this matter is here: http://trueeconomics.blogspot.ie/2015/03/24315-theres-no-number-left-untouched.html

IMF's Selected Issues paper published today alongside Article IV paper covers some of this in detail.

In dealing with the issues of technical challenges in estimating potential output in Ireland, the IMF states that "Irish GDP data volatility and revisions make it difficult to assess the cyclical position of the economy in the short-run. Ireland’s quarterly GDP growth data are among the most volatile of all European Union countries, more than twice the variability typically seen."

The IMF provides a handy chart:

And due to long lags in reporting final figures, as well as volatility, our GDP figures, even those reported, not just projected, are rather uncertain in their nature:

However, as IMF notes: other structural issues with the economy, besides poor reporting timing and quality and inherent volatility, further 'complicate' analysis:

"Multinational enterprises (MNE) accounting for one-quarter of Irish GDP can vary their output substantially with little change in domestic resource utilization. As shown in a recent study, MNEs represent only 2.1 percent of the number in enterprises in Ireland but slightly over half of the value added in the business economy. MNE output swings, sometimes related to sectoral idiosyncratic shocks (e.g., the “patent" cliff” in 2013...), can occur with little apparent change in
domestic resource utilization."

In other words, there is little tangible connection between output of many MNEs and the real economy. And the latest iteration of tax optimisation schemes deployed by the MNCs is not helping the matters: "The sharp increase in offshore contract manufacturing observed in 2014 is another example of such a shock. Such shocks to the productivity of the MNE sector may be best treated as shifts in potential GDP, because the result is a change in GDP without any significant change in resource tensions or slack in the
economy."

But MNCs are important for Ireland's tax base, right? Because apparently they are not that important for determining real rates of growth. Alas, the IMF has the following to say on that: "Swings in the value added of MNEs contribute substantially to variations in Irish GDP. Yet such swings are not found to have a significant effect on [government] revenues."


How big of an effect do MNCs have on the real economic growth as opposed to registered growth? IMF obliges: "The gross value added excluding the sectors dominated by MNEs behaves quite differently from aggregate GDP in some years. For example, in 2013 it grows by 3 percent at a time when official GDP data
were flat." In other words, the real, non-MNCs-led economy shrunk by roughly the amount of growth in the MNCs to result in near-zero growth across the official GDP.

However, since 2013 (over the course of 2014) a new optimisation scheme emerged as the dominant driver of manufacturing MNCs-led growth: contract manufacturing. IMF Article IV itself contains a handy box-out on that scheme, so important it is in distorting our GDP and GNP figures. Per IMF: "In 2014, multinational enterprises (MNEs) operating in Ireland made greater use of offshore
manufacturing under contract."

A handy CSO graphic illustrates what the hell IMF is talking about:

As covered in the link to my earlier blog post above, "Goods produced through contracted manufacturing agreements are treated differently in the national accounts than in customs measures of trade. As these goods do not cross the Irish border, they are not included in customs data on exports. If, however, the goods remain under the ownership of the Irish company, they are recorded as exports in the national accounts. Payments for manufacturing services and patent and royalty payments are service imports in the national accounts, offsetting in part the positive GDP impact of contracted manufacturing."

And to confirm my conclusions, here is IMF on the impact of contract manufacturing (just ONE scheme of many MNCs employ in Ireland) on Irish growth figures: "Contracted manufacturing appears to have had a significant impact on GDP growth in 2014 although it is difficult to make a precise estimate. Customs data on goods exports rose by 2.8 percent y/y in volume terms in the first nine months of 2014. In contrast, national accounts data on exports rose 12 percent in the same period. The gap between these two export measures can be attributed in part to contracted production, but could also reflect other factors like warehousing (goods produced in Ireland but stored and sold overseas) and valuation effects." Note: I cover this in more detail in my post.

"Assuming conservatively that contract manufacturing accounted for about half of the difference between customs and national accounts data, the implied gross contribution to GDP growth in the first three quarters of 2014 from contract manufacturing is 2 percentage points. However, there is a need to take into account the likelihood that service imports were higher than otherwise, but it is not possible to identify the volume of additional service imports linked to contract manufacturing."

One scheme by MNCs accounts for more than 2/5ths of the entire Irish 'miracle of growth'. Just one scheme!

And now… to the punchline:

Update: Seamus Coffey commented on the 2013 figure for domestic (real) economy cited above with an interesting point of view, also relating to the broader issue of the Contract Manufacturing: http://twishort.com/DTShc and his blogpost on the subject is here: http://economic-incentives.blogspot.ie/2015/03/the-growth-effect-of-contract.html