Aggressive Tax Planning Practices and Inward-FDI Implications for Ireland of the New US Corporate Tax Regime

Abstract

National corporate tax systems interact with each other in complex ways. Interactions with the US tax system are particularly important for Ireland given the significance of the US MNC presence in the Irish economy. The US system changed dramatically with the passage of the Trump administration’s Tax Cuts and Jobs Act. This paper outlines the history of corporate tax policy in the two jurisdictions and how the systems interacted up to the time of the recent changes. It also details the type of aggressive tax planning practices that grew up around the location of intellectual property assets. The likely implications of the new US tax regime for intellectual property location and inward FDI in Ireland are then assessed.