Double Irish arrangement

The double Irish arrangement was a tax strategy that some multinational corporations used to lower their corporate tax liability. The strategy has ceased to be available since 1 January 2015, though those already engaging in the arrangement have until 2020 to find another arrangement. The strategy used payments between related entities in a corporate structure to move income from a higher-tax country to a lower or no tax jurisdiction. It relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions. Specifically, Ireland has territorial taxation, and does not levy taxes on income booked in subsidiaries of Irish companies that are outside the state.

The double Irish tax structure was first used in the late 1980s by companies such as Apple Inc. In 2010 Ireland passed a law intended to counter such arrangements, though existing arrangements were exempt and lawyers have said that this change will cause no significant problems for multinational firms.

In 2013, the Irish government announced that companies which incorporate in Ireland must also be a tax resident there. This counter-measure took effect in January 2015, for newly incorporated companies, and will take effect in 2020 for companies with existing operations in Ireland. Irish Finance Minister Michael Noonan, during the presentation of his 2015 budget, said that he believed this would align Ireland's corporate tax regime with international best practice.

Typically, a company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company, which then enters into a cost sharing agreement between the American parent, written strictly in terms of American transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the American, but without paying American tax on the profits unless and until they are remitted to the United States of America.

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Wikipedia