Friday, December 29, 2023

Ireland in 2023: Music and tax haven shenanigans

'Fairytale of New York' played at funeral: Glen Hansard & Lisa O'Neill in lead

(reload the page if the music doesn't start)

John Sheahan (born 1939), the last surviving member of 'The Dubliners' (the famous group that was founded in 1962) played at the funeral.

"The Rare Auld Times - John Sheahan – 80th Birthday Concert Celebration"

I was in Ireland in the first 3 weeks of December 2023. I was there to attend the funeral of my youngest brother in West Cork.

In Dublin despite the cold, the Christmas spirit was high. I visited The Ginger Man pub and the crowd spilled onto the pavement. A kind doorman prioritised me (I shocked him later by giving him a tip!).

Inside, the iconic Irish Christmas ‘Fairytale of New York’ played with the late frontman for the Pogues Group – Shane MacGowan and the late Kirsty MacColl singing.

James Patrick Donleavy (1926-2017), a New Yorker whose parents were Irish migrants, had served in the US Navy during World War II and came to Ireland in 1946. Trinity College in Dublin after the war was a mecca for adventurous Americans who used the GI Bill as a passport to higher education and he enrolled in the university.

Donleavy's book ‘The Ginger Man’ (1955) was banned in Ireland. ‘A Fairytale of New York’ (1973) had an Irish theme. In the 1980s the London-Irish group the Pogues popularised the song version.

Five years ago Saoirse Ronan, the Irish-American actress, sang 'Fairytale of New York' with Jimmy Fallon, the host of NBC's 'The Tonight Show.'

The Pogues achieved 2nd place in the UK single charts in 1987, and last week 'Fairytale of New York' got a 6th ranking.

Sinéad O'Connor (1966–2023); Shane MacGowan (1957–2023), and Christy Dignam (1960–2023) were leading Irish musicians who died in the year.

In The Ginger Man, Dublin, Ireland

1) In 2022 Luxembourg and Ireland posted the highest level of GDP (gross domestic product) per capita expressed in PPS (purchasing power parity involves an economic theory that compares different countries' currencies through a 'basket of goods.' In the EU the respective levels were at 156% and 135% above the average. However, over 40% of Luxembourg's workforce live beyond its border while foreign-owned multinationals distort Irish data.

The IMF (International Monetary Fund) said Ireland's gross domestic product (GDP) per capita in April 2023 was the highest of 195 countries. This was based on PPP.

Ireland was at $145,200 per capita; the UK was at $56,500 but Ireland's adjusted data was $33,500 per head. Denmark was $73,400.

Official Irish figures for population in April 2023 was 5,281,600, up from 5,184,000 in 2022. By year end the population likely is about 5,330,000. The Danish population is about 5,940,000.

Irish wealthiest in the World in 2023! (April ) Brits ahead in GDP per capita

In October 2023 IMF GDP data per capita at current prices has Ireland on top at $112,500 followed by Switzerland at $102,870; Norway $99,300,000 and the United States at $80, 410.

Full data for 2023 will be available in April and October 2024. Ireland's national accounts will be available in March and July.

2) There are more realistic data for Ireland.

Eurostat, the EU's statistical service says "Actual individual consumption, abbreviated as AIC, refers to all goods and services actually consumed by households. It encompasses consumer goods and services purchased directly by households, as well as services provided by non-profit institutions and the government for individual consumption (e.g., health and education services). In international comparisons, the term is usually preferred over the narrower concept of household consumption, because the latter is influenced by the extent to which non-profit institutions and general government act as service providers."

For 2022 Ireland's status improved in the final report in December 2023.

However, its 94% result is still behind the EU average and Italy's.

Austria and Germany (both 18% above), the Netherlands (16% above) and Belgium (15% above). In 2022, nine EU countries recorded an AIC per capita above the EU average.

Ireland was 24% below the per capita levels of Austria and Germany.

3) The Irish Central Statistics Office (CS0) says "Contract manufacturing (also called goods for processing) — where a change in ownership occurs at a different point in time compared to the timing of a cross border movement of goods. Merchanting — to include the transactions related to merchanting1 because they are not already included in the international trade i.e. these transactions do not cross the border of the Irish merchant."

In 2022 the headline value of Irish GDP was €506,300bn and most of €143,000bn was fake.

Modified GNI* (Gross National Income) was introduced as an indicator designed specifically to measure the size of the Irish economy by excluding Globalisation effects. There would be adjustments in these four areas:

– Intellectual Property product relocations;

– Aircraft Leasing;

– Re-domiciled Firms

– Contract Manufacturing in Exports and Imports data.

Contract Manufacturing was subsequently excluded, making the Modified GNI* redundant.

Irish Government may have nixed a key remedy for 'Leprechaun economics'

In recent years Modified Domestic Demand has replaced the Modified GNI* but that also has distortions.

Dr Eddie Casey, Chief Economist and Head of the Secretariat at the Irish Fiscal Advisory Council, warned in May 2023:

"However, users should remain cautious in interpreting the measure. The outsized role of multinational enterprises in very specific areas can still distort modified domestic demand through their effect on modified investment. And by ignoring the trade side entirely, these investments are not offset by imports in the modified domestic demand measure. We show how imports of machinery and equipment to develop semiconductors may have distorted modified domestic demand growth in 2022."

Ireland’s modified domestic demand: what it tells us and where we should be cautious

4) Data on international tax has been published in 2023:

Multinational enterprises continue reporting low-taxed profit, even in jurisdictions with high corporate tax rates, underlining the need for global tax reform

The OECD says "The new data and estimates on taxation of large MNE profits show how tax incentives and other concessions in jurisdictions with high statutory and average tax rates enable some firms to pay low effective tax rates (ETRs). The findings highlight how the introduction of a global minimum tax rate on the profits of large MNEs agreed by the OECD/G20 Inclusive Framework would create new opportunities for domestic resource mobilisation for high-tax and low-jurisdictions alike." November 21, 2023

Effective tax rates of multinational corporations: Country-level estimates

"Ireland, with ETR values of 16%, 15%, 14% and 19% and a statutory rate of 12.5%, presents a more intriguing case; however, given the data limitations, these results are consistent with existing literature. Our data does not account for the case of the Apple company and the Irish public audit body has recently found ETRs of similar magnitude.

The audit body also counters the evidence of low taxation in Ireland presented by for example arguing that the United States Bureau of Economic Analysis data used for this approach, includes financial data from MNCs’ operations everywhere, not just in Ireland, and, as such does not necessarily constitute a reflection of MNCs’ operating activities in Ireland or corporation tax paid in Ireland. November 29, 2023. "

This is nonsense — Ireland became the most profitable country on earth between 1999-2002 for American multinationals (MNCs).

Leprechaun economics continue to distort Ireland's statisticsLeprechaun economics continue to distort Ireland's statistics

The United Kingdom ($565.2bn) and Ireland ($353.0bn) were the fourth - and fifth-largest investing countries in the United States.

Fairytales of the Irish economy obscure the truth

In 2023 tech giant Apple reported that profits at its main Irish subsidiary, Apple Operations International, rose to $69.3bn (€63.5bn) in the year to September 2022. last year.

Apple Operations International Ltd and its subsidiaries delivered daily pretax profits of $189.87mn over the 12 months ($222.75bn.

The company acts as a holding company for several Apple subsidiaries. It manufactures and develops everything from the company’s iPhone and iPad products to Mac computers.

Corporation tax in Ireland has risen by €16bn since 2015, to €23.5bn.

"Surely we can see from the activities of these companies in Ireland how much tax they should pay?" Cliff Taylor of The Irish Times asked rhetorically in early December.

"Actually, no. A key reason why big firms such as Microsoft, Pfizer, Apple, Google and so on pay so much tax here is that they route most of the profits they make outside the US through international headquarters in Ireland. And the Irish exchequer gets a slice of tax from this. This in turn is not popular in other countries, with leading.

French economist Thomas Piketty accusing Ireland of 'siphoning the tax base of others' – in other words, collecting taxes that should be paid in other countries.

We can get some indication of multinational tax payment trends from the international results companies publish for their investors. But they do not yet break down in these reports what tax they pay in different countries – though new obligations in the years ahead will make them do so to some extent. So Irish tax payments can be altered by, say, the fortunes of the latest iPhone, the success of Microsoft in selling its new AI-based products around the world, or the production schedule of Pfizer’s latest drug."

5) In the past decade, the fictional movement of IP (intellectual property) and fake overseas Contract Manufacturing /merchanting has been a boon for large US tech and drug companies.

EU Tax Observatory: 'Global Tax Evasion Report 2024'

The report identifies 13 tax havens worldwide which facilitate corporate profit shifting. Ireland and the Netherlands are the largest “with over $140bn shifted to each in recent years.”

The report says "First, the largest profit-shifting destinations appear to be Ireland and the Netherlands, with over $140bn shifted to each in recent years. In 2019, these two countries each accounted for approximately 15% of the total amount of profits shifted globally. Second, while there is some year-to-year fluctuation, the relative importance of the main havens has remained fairly persistent over time."

The EU Tax Observatory’s “Global Tax Evasion Report” estimated that about $1trn (trillion; €943 billion) of corporate profits were shifted to low-tax countries, including Ireland, in 2022, equivalent to almost 10% of corporate tax revenues collected globally.

In 2021 the OECD/Group of 20 achieved agreement among almost 140 countries on a road map for international tax reform.

According to the 'Global Tax Evasion Report 2024':

"We uncover positive evolution worth celebrating, but also setbacks, and major issues that remain unaddressed.

• First, offshore tax evasion by wealthy individuals has shrunk. Thanks to the automatic exchange of bank information, we estimate that offshore tax evasion has declined by a factor of about three over the last 10 years. This success shows that rapid progress can be made against tax evasion if there is the political will to do so.

• Second, the global minimum tax of 15% on multinationals, which raised high hopes in 2021, has been dramatically weakened. Initially expected to increase global corporate tax revenues by close to 10%, a growing list of loopholes has reduced its expected revenues by a factor of 2 (and by a factor of 3 relative to a comprehensive minimum tax of 20%).

• Third, tax evasion – including grey-zone evasion at the border of legality – is increasingly happening domestically. Global billionaires have effective tax rates equivalent to 0% to 0.5% of their wealth, due to the frequent use of shell companies to avoid income taxation."

The authors of the 'Global Tax Evasion Report 2024' say "Thanks to the automatic exchange of bank information, offshore tax evasion has declined by a factor of about three in less than 10 years. Before 2013, households owned the equivalent of 10% of world GDP in financial wealth in tax havens globally, the bulk of which was undeclared to tax authorities and belonged to high-net-worth individuals.

Today there is still the equivalent of 10% of world GDP in offshore household financial wealth, but in our central scenario, only about 25% of it evades taxation. This reduction in noncompliance is a major success that shows that rapid progress can be made against tax evasion if there is the political will to do so (Figure 1)."

The Irish Times on December 28 published an article on economic prospects in 2024:

'Irish economy has stalled and corporation tax is wobbling but what will 2024 bring?'

"The last four years have brought four shocks: Brexit, Covid, inflation and Russia’s invasion of Ukraine. Despite the warnings, all the dire forecasts, the Irish economy has motored through each one, growing by 3.4% in GDP (gross domestic product) terms in 2020 at the height of the pandemic when the rest of the world was languishing in recession; by 15% in 2021; and by 9.4% in 2022.[...]"

These GDP data are highly distorted. In 2022 the headline rate was €506,300bn.

Adjustments for multinational (MNC) activity that had little impact on the Irish economy:

1) Factor income of Redomiciled Companies 2) depreciation on R&D Service Imports and Trade in Intellectual Property (IP); and 3) depreciation on Aircraft Leasing reduced the GDP to €273bn (Modified GNI*).

Contract Manufacturing/ Merchanting (e.g. Ireland shipping Apple products to China) in total was €143bn (let's generously say about €3bn was real), the real GDP value was €140bn; €27,200 per head or $28,600.

From World Bank data per capita, the UK was at $46,100; Italy $34,800; Euro Area $41,000; EU $37,400; High Income $49,600.

Ireland $28,600; Austria $52,000; Belgium $52,000; Czechia $27,200; Denmark $67,800; Finland $50,900; Lithuania $25,000; Portugal $24,500; Greece $20,900; Hungary $18,400.

Ireland is among the second-tier advanced countries.

What happens when the music stops?


Ireland has become one of the two top business tax havens. Yes, legitimate foreign companies operate in Ireland but at some point, the bigger countries are not going to tolerate the stealing of their taxes.

Check Table 3 here with respect to American overseas affiliates in 2021. Netherlands and Irelands have the highest net income. Ireland has almost ten times Germany's; Ireland has 160,000 employees; Germany has 644,600; the UK has 1.328mn, in US affiliates, but the productivity is awful!!

Ireland is among the world leaders in R&D which is bullshit.

Exports to the Eurozone by Irish-owned firms were only €7.9bn in 2022. In 2023 the population of the 19 other members is 334mn.

The rise in the Irish population remains ahead of house building.

In the period 2011-2023, the population rose by about 700,000 while housing completions were about 200,000.

Employment has been strong at below 5% and in December the overall population rose by more than 100,000 people to more than 5.3mn – the largest 12-month increase since 2008.

There was a net migration of 77,600 in the year to April 2023 – up from a net migration of 51,700 in 2022 and 21,800 in 2021. This rise in net migration has contributed to a 25% increase in population change, rising to 97,600 in 2023 from 77,800 in 2022.

According to the European Commission, by September 2023, over 93,000 Ukrainians fleeing from war had arrived in Ireland.

The rate of increase of Ukrainians arriving in Ireland over the past 12 months was 10 times higher than the average increase in numbers fleeing to the EU from Ukraine over the same period.

Foreign-born in Ireland overtake Irish-born in countries overseas (December 2022)

Denmark and Ireland had the highest consumer prices in the EU in 2022 (Comparative price levels of consumer goods and services).

Denmark is one of the world's most innovative economies.

Danish drugmaker Novo Nordisk overtook LVMH as Europe's most valuable listed company in September following soaring demand for its obesity drug. As of December 29, 2023, Novo Nordisk has a market cap of $466bn.

Nordisk's foundation was in the 1920s and Novo followed in 1951. The foundations merged in 1989. LEO Pharma A/S, the multinational Danish pharmaceutical company, was founded in 1908.

The closest Ireland got to a significant indigenous drugs company was in 2001 when Élan became the 20th most valuable pharmaceutical in the world with a valuation of €20bn.

In January 2002 'The Wall Street Journal' reported the existence of 55 joint ventures that Élan had structured to simultaneously shift R&D costs off its books and bring in revenue before any drugs are developed.

In 2005 Élan and its US partner had to remove a multiple sclerosis drug from the market.

Élan was founded in Ireland in 1969 as a drug-delivery business, by American chemist Don Panoz, to facilitate the development of the technology behind the nicotine patch. It became a public limited company in January 1984.

Following several disposals by 2013, US generic drugmaker Perrigo agreed to buy Élan in a $8.6bn deal.

Absent a strong indigenous sector, Ireland will remain in the second league.

The success of Irish economy masks the extent of underlying weakness

The Strange, Broken Economics of Ireland

It was Microsoft together with a Dublin law firm that pioneered the 'Double Irish Dutch Sandwich,' not Apple. In 2005 'The Wall Street Journal' broke the story on the use of Irish shell companies in Bermuda.

Apple routed funds in its two key Irish shell companies, Apple Operations International (AOI) and its subsidiary (Apple Sales International), mainly to the United States.

A Senate Permanent Subcommittee on Investigations reported in May 2013 "For more than thirty years, Apple has taken the position that AOI has no tax residency, and AOI has not filed a corporate tax return in the past 5 years." 

Government data  2021

Foreign companies in Ireland that are supported by the IDA state agency, had full-time staff at 294,070 in 2022. Enterprise Ireland, which supports Irish-owned companies, had 190,900 full-time staff.

There were about 2mn full-time employees in the economy at the end of 2022. 

The Revenue said in respect of 2021 that foreign-owned multinationals had over 850,000 employees. It says beyond the FDI sector, "The remaining 360,400, of which the largest share was 174,800 in Wholesale & Retail Trade, are most likely foreign-owned multinationals operating in Ireland to serve the domestic market."

This was 34% of an estimated 2,505,800 (first quarter 2022 including part-time staff) who were working in foreign-owned companies.

Foreign companies supported by IDA:

Payroll  €20.126bn; average €83,000 per employee

Irish Materials €3.983bn (13.5% of the total); Services 9.530bn  (5.39%)

Irish companies supported by Enterprise Ireland:
Payroll €9.530bn average €53,600 per head.

Irish Materials  €14.323bn; (62.5% of the total); Services 5,697 (61.2%)