Belfast Telegraph

View from Dublin: Paschal balances books on 'Leprechaun Economics'

By Richard Curran

While so much focus has been on Paschal Donohoe's stamp duty increase in the Budget, it wasn't the only place he was able to put his hands, quite easily, on a very large sum of money to balance the books.

The stamp duty increase on commercial property is expected to raise around €375m (£333m) next year. But there was another €150m (£133m) tapped from multinationals on intangible assets or intellectual property (IP).

This is kind of linked to the so-called 'Leprechaun Economics' phenomenon of 2015. Back then the government decided to allow companies to offset all of the money they spend either developing or acquiring IP against the trading profits they make from it.

As soon as multinationals could write off the full amount, an extraordinary €300bn (£266bn) worth of capital assets was transferred to Ireland from around the world, and it was mainly IP.

We couldn't really tax any of it because it was all written off against cost. But it counted in GDP so it artificially ballooned our economic growth figure. However, it wasn't just a technical exercise in balance sheet and accounting management. Ownership of €300bn of IP shifted to Ireland.

Multinationals make very real profits from charging for the use of their IP. In 2015, the trading profit in Ireland on their IP shot up by €26bn (£23bn). This was completely offset by capital allowances they received - basically reducing their taxable profit on that to close to zero.

To put it in perspective if we had allowed just 80% of that to be set against capital allowances, we could have taxed 20% of it at 12.5%. It could have yielded around €650m (£577m) in tax.

This was one very smart leprechaun because it meant companies further embedded their connections with Ireland and we opened the door to billions in new IP. We cannot tax them on that IP for several years, until they have offset all of it in capital allowances over anything from five to 10 years.

But once that period is up, as long as the IP stays in Ireland, we will be able to start taxing the profits these companies make.

In the Budget, minister Donohoe has moved to reduce the amount companies can avail of in capital allowances on intangible assets to 80% instead of 100%. This is in line with the recommendations of Seamus Coffey's report on corporation tax.

The €300bn that came into the country in 2015 is off limits for now, but any new transfers will be taxable up to a point.

Belfast Telegraph

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