Corporation tax in the Republic of Ireland
Encyclopedia
Corporation tax in the Republic of Ireland is a levy on a company’s profits. The tax
Tax
To tax is to impose a financial charge or other levy upon a taxpayer by a state or the functional equivalent of a state such that failure to pay is punishable by law. Taxes are also imposed by many subnational entities...

 is charged on both a company's income and chargeable gains. The corporation tax in Ireland
Republic of Ireland
Ireland , described as the Republic of Ireland , is a sovereign state in Europe occupying approximately five-sixths of the island of the same name. Its capital is Dublin. Ireland, which had a population of 4.58 million in 2011, is a constitutional republic governed as a parliamentary democracy,...

 is quite low, and is often cited as an example of tax competition, as it is used as an incentive for foreign companies to invest in the state.

Tax rates

There are three rates of corporation tax in the Republic of Ireland:
  • 12.5% for trading income

  • 25% for non-trading income

  • A special rate of 10% for companies involved in manufacturing, the International Financial Services Centre
    International Financial Services Centre
    The International Financial Services Centre is a major financial services centre in North Wall, Dublin, Ireland. The centre employs 14,000 people and was the brainchild of an associate of businessman Dermot Desmond...

     (IFSC) or the Shannon Free Zone
    Shannon Free Zone
    Shannon Free Zone is a , international business park adjacent to Shannon International Airport, County Clare, Ireland which is 18 km from Ennis and 20 km from Limerick city. Businesses based on the site enjoy a very attractive tax package on their profits. This has served to attract a...

     ended on 31 December 2003.

History

Over the past decade, Ireland’s corporate taxation system has been a source of controversy with some of Ireland’s fellow-member states in the European Union
European Union
The European Union is an economic and political union of 27 independent member states which are located primarily in Europe. The EU traces its origins from the European Coal and Steel Community and the European Economic Community , formed by six countries in 1958...

. The French government has over the past decade, most particularly during the premiership of Lionel Jospin
Lionel Jospin
Lionel Jospin is a French politician, who served as Prime Minister of France from 1997 to 2002.Jospin was the Socialist Party candidate for President of France in the elections of 1995 and 2002. He was narrowly defeated in the final runoff election by Jacques Chirac in 1995...

, consistently condemned and criticised the Irish corporation tax system. This criticism is based on the belief that the low corporation tax rates enabled Ireland to compete unfairly in attracting international investment. However, despite the French critique of the Irish corporate tax system, the Irish example has won many followers, with many ‘emerging’ and Eastern European economies following the Irish example.

Post-independence under Cumann na nGaedheal

It was only with the acceptance of the Anglo-Irish Treaty
Anglo-Irish Treaty
The Anglo-Irish Treaty , officially called the Articles of Agreement for a Treaty Between Great Britain and Ireland, was a treaty between the Government of the United Kingdom of Great Britain and Ireland and representatives of the secessionist Irish Republic that concluded the Irish War of...

 by both the Dáil and British House of Commons
British House of Commons
The House of Commons is the lower house of the Parliament of the United Kingdom, which also comprises the Sovereign and the House of Lords . Both Commons and Lords meet in the Palace of Westminster. The Commons is a democratically elected body, consisting of 650 members , who are known as Members...

 in 1922 that the mechanisms of a truly independent state begin to emerge in the Irish Free State
Irish Free State
The Irish Free State was the state established as a Dominion on 6 December 1922 under the Anglo-Irish Treaty, signed by the British government and Irish representatives exactly twelve months beforehand...

. In keeping with many other decisions of the newly independent state the Provisional Government and later the Free State government continued with the same practices and policies of the British administration with regard to corporate taxation.

This continuation meant that the British system of corporate profits taxation (CPT) in addition to income tax
Income tax
An income tax is a tax levied on the income of individuals or businesses . Various income tax systems exist, with varying degrees of tax incidence. Income taxation can be progressive, proportional, or regressive. When the tax is levied on the income of companies, it is often called a corporate...

 on the profits of firms was kept. The CPT was a relatively new innovation in the United Kingdom
United Kingdom
The United Kingdom of Great Britain and Northern IrelandIn the United Kingdom and Dependencies, other languages have been officially recognised as legitimate autochthonous languages under the European Charter for Regional or Minority Languages...

 and had only been introduced in the years after World War I
World War I
World War I , which was predominantly called the World War or the Great War from its occurrence until 1939, and the First World War or World War I thereafter, was a major war centred in Europe that began on 28 July 1914 and lasted until 11 November 1918...

, and was widely believed at the time to have been a temporary measure. However, the system of firms been taxed firstly through income taxed and then through the CPT was to remain until the late seventies and the introduction of Corporation Tax, which combined the income and corporation profits tax in one.

During the years of William Cosgrave's governments, the principal aim with regard to fiscal policy was to reduce expenditure and follow that with similar reductions in taxation. This policy of tax reduction did not extend to the rate of the CPT, but companies did benefit from two particular measures of the Cosgrave government. Firstly, and probably the achievement of which the Cumann na nGaedheal administration was most proud, was the reduction by 50% in the rate of income tax from 6 shillings in the pound to 3 shillings. While this measure benefited all income earners, be they private individuals or incorporated companies, a number of adjustments in the Finance Acts, culminating in 1928, increased the allowance on which firms were not subject to taxation under the CPT. This allowance was increased from £500, the rate at the time of independence, to £10,000 in 1928. This measure was in part to compensate Irish firms for the continuation of the CPT after it has been abolished in the United Kingdom.

A measure which marked the last years of the Cumann na nGaedheal government, and one that was out of kilter with their general free trade policy, but which came primarily as a result of Fianna Fáil
Fianna Fáil
Fianna Fáil – The Republican Party , more commonly known as Fianna Fáil is a centrist political party in the Republic of Ireland, founded on 23 March 1926. Fianna Fáil's name is traditionally translated into English as Soldiers of Destiny, although a more accurate rendition would be Warriors of Fál...

 pressure over the ‘protection’ of Irish industry, was the introduction of a higher rate of CPT for foreign firms. This measure survived until 1948, when the Inter-Party government
Government of the 13th Dáil
The 13th Dáil was elected at the 1948 general election on 4 February 1948 and first met on 18 February when the 5th Government of Ireland was appointed. The 13th Dáil lasted for 1,211 days....

 rescinded it, as many countries with which the government was attempting to come to double taxation treaties viewed it as discriminatory.

Fianna Fáil under Éamon de Valera

The near twenty years of Fianna Fáíl government between from 1931 to 1948, cannot be said to have been a time where much effort was expended on changing or analysing the taxation system of corporations. Indeed only one policy sticks out during those year of Fianna Fáil rule; being the continued reduction in the level of the allowance on which firms were to be exempt from taxation under the CPT, from £10,000 when Cumman na nGaehael left office, to £5,000 in 1932 and finally to £2,500 in 1941. The impact of this can be seen in the increasing importance of CPT as a percentage of government revenue, rising from and less than 1% of tax revenue in the first decade of the Free State to 3.64% in the decade 1942-43 to 1951-52. This increase in revenue from the CPT was due to more firms being in the tax net, as well as the reduction in allowances. The increased tax net can be seen from the fact that between 1932–33 and 1938–39, the number of firms paying CPT increased by over 33%. One other aspect of the Fianna Fáil government which bears all the fingerprints of Seán Lemass
Seán Lemass
Seán Francis Lemass was one of the most prominent Irish politicians of the 20th century. He served as Taoiseach from 1959 until 1966....

, was the 1946 decision to allow mining companies to write off all capital expenditure against tax over five years.

Seán Lemass and after

The period between after the late 1950s and up to the mid-1970s can be viewed as a period of radical change in the evolution of the Irish Corporate Taxations system. The increasing realisation of the government that Ireland would be entering into an age of increasing free trade encouraged a number of reforms of the tax system such as the Free Movement of Cows Act 1965. By the mid-1970s, a number of amendments, additions and changes had been made to the CPT, these included fifteen year tax holidays for exporting firms, the decision by the government to allow full depreciation in 1971 and in 1973, and the Section 34 of the Finance Act, which allowed total tax relief in respect of royalties and other income from licenses patented in Ireland.

This period from c.1956 to c.1975, is probably the most influential on the evolution of the Irish corporate taxation system, and marked the development of an ‘Irish’ system, rather than continuing with a British model.

This period saw the creation of Corporation Tax, which combined the Capital Gains, Income and Corporation Profits Tax that firms previously had to pay. Future changes to the corporate tax system, such as the measures implemented by various governments over the last twenty years can be seen as a continuation of the policies of this period. The introduction in 1981 of the 10% tax on manufacturing was simply the easiest way to adjust to the demands of the EEC to abolish the export relief, which the EEC viewed as discriminatory. With the accession to the EEC, the advantages of this policy became increasingly obvious to both the Irish government and to foreign multi-nationals; by 1982 over 80% of companies who located in Ireland cited the taxation policy as the primary reason they did so.

Corporation tax was reduced to 12.5% on trading income,. This is generally believed to have been an important stimulus for the Celtic Tiger
Celtic Tiger
Celtic Tiger is a term used to describe the economy of Ireland during a period of rapid economic growth between 1995 and 2007. The expansion underwent a dramatic reversal from 2008, with GDP contracting by 14% and unemployment levels rising to 14% by 2010...

.

In the 1998 Budget (in December 1997) Finance Minister, Charlie McCreevy
Charlie McCreevy
Charles "Charlie" McCreevy is a former Irish politician. He was the European Commissioner for Internal Market and Services from 2004–2010. He was first elected to Dáil Éireann as a Fianna Fáil TD in 1977 and held the seat in Kildare until 2004 when he became Ireland's European Commissioner...

 introduced the legislation for a new regime of corporation tax that led to the introduction of the 12.5% rate of corporation tax for trading income from 1 January 2003. The legislation was contained in section 71 of the Finance Act 1999 and provided for a phased introduction of the 12.5% rate from 32% for the financial year 1998 to 12.5% commencing from 1 January 2003. A higher rate of corporation tax of 25% was introduced for passive income, income from a foreign trade and some development and mining activities. Manufacturing relief, effectively a 10% rate of corporation tax, was ended on 31 December 2002. For companies that were claiming this relief before 23 July 1998 it would still be available until 31 January 2010. The 10% rate for IFSC activiites ended on 31 December 2005 and after this date these companies moved to the 12.5% rate provided their trade qualified as an Irish trading activity.

Inward investment

The low corporate tax rate in Ireland has contributed to inward investment in Ireland and the Celtic Tiger
Celtic Tiger
Celtic Tiger is a term used to describe the economy of Ireland during a period of rapid economic growth between 1995 and 2007. The expansion underwent a dramatic reversal from 2008, with GDP contracting by 14% and unemployment levels rising to 14% by 2010...

 phenomenon. The low tax rate and Ireland's relaxed transfer pricing
Transfer pricing
Transfer pricing refers to the setting, analysis, documentation, and adjustment of charges made between related parties for goods, services, or use of property . Transfer prices among components of an enterprise may be used to reflect allocation of resources among such components, or for other...

 rules have also encouraged the use of Ireland in international tax planning
International taxation
International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries or the international aspects of an individual country's tax laws. Governments usually limit the scope of their income taxation in some manner territorially or provide...

, for example the use of the Double Irish Arrangement
Double Irish Arrangement
The Double Irish Arrangement is a tax avoidance strategy that U.S. based multinational corporations use to lower their income tax liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on...

.

Yearly returns

Year Corporation Profits Tax Corporation Tax Total Tax Revenue Total Revenue
1922-23 254,050 30,017,372 30,017,372
1923-24 358,000 31,414,255 31,414,255
1924-25 248,000 26,948,114 26,948,114
1925-26 488,000 25,439,097 25,439,097
1926-27 400,000 25,060,379 25,060,379
1927-28 273,000 24,123,270 24,123,270
1928-29 239,000 24,221,046 24,221,046
1929-30 220,000 24,172,640 24,172,640
1930-31 288,000 24,365,197 24,365,197
1931-32 246,000 25,496,420 25,496,420
1932-33 460,000 29,990,935 29,990,935
1933-34 467,000 30,229,181 30,229,181
1934-35 481,000 28,770,689 28,770,689
1935-36 513,000 30,601,620 30,601,620
1936-37 535,000 31,034,710 31,034,710
1937-38 635,000 31,208,583 31,208,583
1938-39 591,000 31,883,864 31,883,864
1939-40 524,000 32,388,747 32,388,747
1940-41 552,000 34,637,659 34,637,659
1941-42 910,000 36,979,659 36,979,659
1942-43 2,760,000 39,728,365 39,728,365
1943-44 3,781,000 43,779,733 43,779,733
1944-45 4,042,000 46,175,493 46,175,493
1945-46 4,475,000 50,812,167 50,812,167
1946-47 4,536,000 54,352,865 54,352,865
1947-48 4,667,000 65,197,845 65,197,845
1948-49 3,450,000 71,691,728 71,691,728
1949-50 2,260,000 74,025,758 74,025,758
1950-51 2,533,000 67,718,000 77,356,608
1951-52 2,660,000 73,161,000 83,905,311
1952-53 2,921,000 84,120,000 95,918,809
1953-54 2,646,000 87,845,000 102,802,908
1954-55 2,944,000 89,876,000 106,727,534
1955-56 3,200,000 94,258,000 111,675,488
1956-57 3,075,000 98,818,000 117,663,725
1957-58 2,930,000 102,653,000 122,920,560
1959-60 3,031,000 107,328,000 129,855,578
1960-61 3,284,000 114,890,000 138,839,495
1961-62 3,667,000 126,152,000 151,685,670
1962-63 4,516,000 136,160,500 163,477,738
1963-64 7,710,000 155,034,000 184,419,459
1964-65 8,439,000 183,410,343 219,045,333
1965-66 9,320,000 203,716,748 240,761,328
1966-67 9,430,000 231,978,491 272,843,217
1967-68 12,076,000 259,579,621 305,408,793
1968-69 12,828,000 294,998,218 345,479,707
1969-70 14,876,000 350,982,121 411,012,014
1970-71 20,342,000 414,094,697 481,505,952
1971-72 21,097,000 486,754,000 569,401,402
1972-73 21,151,000 559,858,729 659,069,627
1973-74 22,750,000 689,670,989 792,913,481
1974 18,979,000 542,254,126 651,407,032
1975 26,530,000 926,657,767 1,091,227,078
1976 13,746,000 15,898,000 1,265,622,855 1,470,197,180
1977 8,039,000 69,644,000 1,481,671,796 1,756,883,362
1978 4,334,000 101,509,000 1,727,820,027 2,023,351,982
1979 2,283,000 128,064,000 2,008,495,043 2,383,919,283
1980 1,425,000 138,418,000 2,619,658,820 3,155,265,174
1981 26,000 199,995,000 3,314,532,886 3,972,706,450
1982 231,778,000 4,053,258,119 4,908,165,606
1983 214,988,000 4,681,436,610 5,711,024,846
1984 209,674,000 5,303,979,384 5,952,268,820
1985 217,203,000 5,581,085,997 6,330,865,381
1986 257,970,000 6,095,589,524 6,709,018,274
1987 257,549,000 7,151,846,053 7,151,846,053
1988 333,674,000 7,689,618,436 7,689,618,436
1989 303,017,000 7,442,621,000 7,755,742,000
1990 474,071,000 7,902,651,000 8,268,799,000
1991 593,395,000 8,357,194,000 8,775,659,000
1992 739,131,000 8,910,299,000 9,360,138,000
1993 951,700,000 9,704,435,000 10,435,748,000
1994 1,139,999,000 10,834,959,000 11,202,092,000
1995 1,145,761,000 11,334,626,000 11,666,874,000
1996 1,425,855,000 12,520,241,000 12,954,399,000
1997 1,698,708,000 14,273,726,000 14,619,166,000
1998 2,064,933,000 16,129,527,000 16,503,181,000
1999 2,709,719,000 18,559,254,000 18,993,427,000
2000 3,061,473,000 21,320,959,000 21,741,171,000
2001 3,273,155,000 21,993,011,000 22,632,862,000


Notes:
  • 1958-59 unavailable
  • 1922-23 - Accuracy of the figures uncertain due to the changeover in government 1922-23
  • All years until 1974, go from 1 April to 31 March.
  • After this, the figures follow the calendar year.
  • 1974 - Only counts March 31 to December 30
  • All subsequent years 1 January to 30 December
  • All figures, pounds


2001 to present (Euro bn)
Year Corporation Tax Total Tax Revenue Total Revenue Reference
2001 4.16 27.93 28.74 (restated)
2002 4.80 29.29 31.53
2003 5.16 32.10 33.16
2004 5.33 35.58 36.38
2005 5.49 39.25 39.85
2006 6.68 45.54 46.14
2007 6.39 47.25 47.89
2008 5.07 40.78 41.62
2009 3.90 33.04 33.88
2010

Sources

  • Stewart, JC, Corporate Finance and Fiscal Policy in Ireland, Aldershot, England, 1987
  • O’ Malley, Industry and Economic Development, Dublin 1989
  • Proposals for Corporation Tax, Dublin, 1974
  • Quigley, Dermot, The Impact of EU Membership on Taxation in The Fiscal Impact of EU Membership on *Ireland, Proceedings of the Tenth annual Conference of the Foundation for Fiscal Studies, Dublin 1997
  • White Paper on Industrial Policy, Dublin, 1984
  • Telesis, A review of Industrial Policy, Dublin, 1982
  • Second Report of the Commission on Taxation – Direct Taxation and the role of Incentives, Dublin, 1984
  • Company Taxation in Ireland, Dublin, 1972
  • Programme for Economic Expansion, Dublin, 1958
  • Revenue Commissioners
  • Finance Accounts 1922-2002

  • OECD Papers:
  • Taxing Profits in a Global Economy – Domestic and International Issues, Paris, 1991
  • Company Tax Systems in OECD Countries, Paris, 1973
  • Harmful Taxation Competition, An Emerging Global Issues, Paris, 1998

See also

  • Taxation in the Republic of Ireland
    Taxation in the Republic of Ireland
    In the Republic of Ireland there is an income tax, a VAT, and various other taxes. Employees pay pay-as-you-earn taxes based on their income, less certain allowances. The taxation of earnings is progressive, with little or no income tax paid by low earners and a high rate applied to top earners...

  • Corporation Tax
  • Tax competition
    Tax competition
    Tax competition, a form of regulatory competition, exists when governments are encouraged to lower fiscal burdens to either encourage the inflow of productive resources or discourage the exodus of those resources...

  • Economy of Ireland
  • Economic history of the Republic of Ireland
    Economic history of the Republic of Ireland
    The state described today as the Republic of Ireland seceded from the United Kingdom of Great Britain and Ireland in 1922. The state was plagued by poverty and emigration until the 1960s and again in the 1970s and 1980s...

  • IDA Ireland - Tax
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