Ireland’s tax rate and Apple

I’ve written about the arrangements which Apple has in Ireland and their need to comply with the arms length principle. Some recent coverage has revealed concerns that some countries still have as a target the corporate tax rate in Ireland rather than arrangements or rulings.
This would be the wrong target and the review should focus on the arrangements.
So long as a corporate tax regime is transparent and open to all (domestic and foreign investors) it is not unfair tax competition. A low rate per se is not wrong if it meets these tests.
Tax competition at the corporate tax level is a good thing, corporation tax is after all a tax borne economically by the shareholders and  employees of a company.
The focus of the EC should be the arrangements and any corporate rules which only benefit certain classes of taxpayer like the Double Irish structure. It is positive to see that the Irish budget announced both the closure of this structure to new entrants and the phasing out of existing arrangements.

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