Tuesday, April 07, 2009

Retooling corporate tax avoidance

There was a supplemental budget in Ireland today. Much more analysis here. But one measure might merit some scrutiny from overseas governments. Finance Minister Brian Lenihan said --

I also mentioned the increased importance globally of intellectual property. Accordingly, I propose to introduce a scheme of tax relief for the acquisition of intangible assets, including Intellectual Property as a means of supporting the Smarty Pants Economy.

This could mean a lot of things. But foreign multinationals already park their intellectual property with Irish subsidiaries so that they attribute as much of their income as possible to the low tax Irish jurisdication. No doubt HM Revenue and the IRS have been taking a close look at that arrangement, perhaps arguing that it needs to be justified in terms of Irish research capabilities. But the new measure sounds like an added wheeze whereby companies could buy intellectual property, get a tax deduction for the purchase AND pay the low corporate tax rate on the income from the property (e.g. royalties from software or pharma).

Just don't call us a tax haven.

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