Talk:Ireland as a tax haven/Archive 1

Ireland as a tax haven
Wanted to create a wiki to capture the material around this issue (a "google" of Ireland tax haven yields a lot of material). The issue on whether a jurisdiction is, or is not, a tax haven, is complex for cases like Ireland (there is no definitive consensus list). There are many tax haven, tax inversion, tax avoidance etc type wiki articles that have Ireland in them, however, it might be worth also aggregating the facts at a country level as well. There is no conclusion on the facts, which is not the purpose of the article, but I think it is useful to have a single page where they are captured in a basic structured manner - split into the source of the labels, evidence of the labels and rebuttals of the labels.Britishfinance (talk) 07:58, 21 June 2018 (UTC)

Also been struggling to keep the size of the main generic/functional pages on tax havens, tax inversion, corporate tax avoidance etc. down as each individual jurisdiction brings up its own complexity and differences (i.e. there is less commonality amongst leading tax havens - especially corporate tax havens, like Ireland). It is getting harder to adequately summarise the issues across all jurisdictions. Looking at major and/or very contested tax haven jurisdictions individually (like Ireland), but still linking into the main functional pages, might be an improvement. The main functional pages can also reduce some of their complexity and refer to individual pages for greater detail around the arguments as to why a jurisdiction's tax haven status is contested, and perhaps just use the lede. This is not needed for say the Caribbean Islands which few contest, but I think it is becoming appropriate for strongly contested cases such as Ireland, Singapore, the U.S., Germany and the U.K. where there is no unanimous conclusion but a lot of strong debate and a large depth of different facts. Britishfinance (talk) 22:07, 23 June 2018 (UTC)

I can see that someone has already done this for the U.S. (United States as a tax haven), and Panama (Panama as a tax haven) as well. Britishfinance (talk) 10:05, 25 June 2018 (UTC)
 * Spent morning reading this and some of other related wikis. This format works as the material in this article could not fit into the generic tax haven/corporate tax haven wikis. Corporate tax havens are very (very) sophisticated places and need individual attention - they don't all focus on the same areas.  I was trying to think of maybe a different title, like "Is ireland a tax haven?", but couldn't. This one seems fine.
 * good article but it seems to say nothing about foreign manufacturing. I work in tech manufacturing for a US company and we are told that the Trumps tax rules don't affect manufacturing and that it is not a target for him? Is this why it does not feature much, and is it really the software/IP stuff that is under attack?  — Preceding unsigned comment added by 31.187.0.185 (talk) 14:37, 16 August 2018 (UTC)

Highly editorialized content, author appears to have strong anti-Irish bias.
While the article is certainly well sourced (in support of one perspective), it is sprinkled with editorialized commentary, and lacking in sources which counter it's core argument (which are plentiful). This author appears to demonstrate a fairly clear agenda in this and other articles specifically around this topic. I have flagged the page for neutrality review. — Preceding unsigned comment added by 109.76.217.142 (talk) 14:53, 26 August 2018 (UTC)
 * : Please give specifics and alternative sources which would be helpful to discuss your point. It is not disputed that Ireland is called a tax haven (I presume you accept that), and the sources of the label have been listed in detail (James Hines is the most cited author in all tax haven research).  The evidence for why Ireland is called a tax haven is also listed in detail.  However, I suspect that your concern is over the "rebuttal" section?  Would be interesting if you have quality sources which you feel were omitted here (or have facts listed in the "rebuttal" that you think are wrong)?  I searched at length but hard to find anything that doesn't take the line of "Ireland is not a tax haven because the OECD does not say so" (which is not WP quality given how discredited the OECD definition has become).  The aim of the article is to chronicle the fact-base on this topic as it was causing problems in the generic wiki tax haven articles to address the specifics of each individual major tax haven (they are all different in each way - the U.K. tax haven article is coming soon). Look forward to hearing from you.Britishfinance (talk) 15:06, 26 August 2018 (UTC)


 * : Thank you for your engagement. In terms of alternative sources or viewpoints,

There are also several relevant editorial perspectives which would inform your section

A. https://www.irishtimes.com/opinion/diarmaid-ferriter-semantics-and-ireland-s-tax-status-1.3531977 (new)

B. https://www.irishtimes.com/opinion/editorial/the-irish-times-view-on-corporate-tax-on-the-defensive-1.3530691

C. https://www.irishexaminer.com/breakingnews/business/irish-tax-haven-label-wrong-848696.html (old)

D. https://www.independent.ie/business/irish/peter-vale-five-reasons-why-ireland-is-not-a-tax-haven-29287879.html (older)

The European perspective

E https://www.charteredaccountants.ie/News/Ireland-is-not-a-Tax-Haven---Moscovici

The Irish government's own perspective

F. http://www.budget.gov.ie/Budgets/2015/Documents/EY_Historical_Dev_International_Context_Irish_%20Corporation_Tax.pdf

G. http://www.budget.gov.ie/Budgets/2015/Documents/EIA_Summary_Conclusions.pdf

H. https://www.irishtimes.com/business/economy/paschal-donohoe-insists-ireland-is-not-world-s-biggest-tax-haven-1.3529061

I. https://www.irishtimes.com/business/economy/ireland-is-not-a-tax-haven-leo-varadkar-says-1.3303226

For an academic look, the Irish dept. of Finance published this

J. https://www.esr.ie/article/view/78

K. https://www.tcd.ie/business/assets/pdf/MNE-tax-strategies-and-ireland.pdf A comprehensive and pretty neutral academic paper

I can add more in the academic category later, but I need to re-review for particular citations, and I'm away from my journal access at the moment.

In terms of legal/policy situation

L. https://www.revenue.ie/en/companies-and-charities/corporation-tax-for-companies/corporation-tax/company-residency-rules.aspx - Guidance from the Irish revenue department

The articles listed above were quite readily available, and I couldn't find any of them in your article, even though they are highly relevant to the topic, and in particular to presenting a balanced view.

Non-Irish sources are thin on the ground, but this intuits reasonably well, as the only international interest in this subject is seemingly to make superficial and simplistic analyses which feed the narrative that Ireland is a tax haven. More accurately, Ireland is a tax *conduit*, in that it's rules regarding multinational revenue domiciling were abused to proxy funds elsewhere (Jersey, Caymans, Bermuda, Malta*). Your article obfuscates this quite extensively.


 * Much-appreciated material and response ! give me a few days to go through this (am about to leave for travel now) and i will come back on each item and will incorporate as appropriate (and amend any relevant wordings). I would also ask you in the meantime to read the academic research in particular - Hines, Dharmapala and Zucman are the three most cited researchers in all tax haven research (with Hines being by far the most cited, and has 4 papers in the top 10 most cited papers).  Hines, in particular, has been a target of most Irish government-supported research into tax havens.  It is a bit crazy as outside of Ireland, Hines is the main figure in tax haven research (still is), but Ireland hates him.  Unusually, Hines, while not being shy of listing tax havens, is a huge supporter of tax havens and the benefits of tax havens (and the benefits of tax havens to US firms).  However, the article is not about the pros and cons of tax havens, it is purely on the term (to keep it encyclopedic).  It is important that the fact base is quality and that the proper weight is given to academic research (a lot of non-academic is biased).  If you read the last section you will see that Ireland is not a tax haven by stealth or ill-gotten means - the US and EU are clear what Ireland does (and their actions show this), the US needs Ireland as a tax haven and the EU is happier that it is Ireland (vs. the Cayman).  The US could cease all US multinational activity in Ireland in 24 hours, but they dont.  And even after TCJA, they still don't.  It does make a very interesting picture - a huge concentration of US firms in Ireland, mixed messages from the US and EU on tax havens (e.g. do as I say, not as I do).  I understand this area well and want to show the fact base as people like me view it as I don't think that the general public gets this view.  They are often stuck in the first level debate of "Ireland is not a tax haven".  Hope this helps, and I will repond on the above later in week.Britishfinance (talk) 16:03, 26 August 2018 (UTC)

{other interested party) Sorry for butting in, but let’s break this down:

1. An anonymous objector starts by saying the article is biased because of a bogus claim about how foreign firms are taxed in Ireland - so ridiculous it shows that he didn’t even read the article or understand basic corporate tax.

2. Then the objector says that there is lots of independent academic research refuting the article which was not posted, when the article lists all of the most cited academic research for 25 years on the topic.

3. The the objector because the POV-check cmd cannot be used without specific reasons, posts “evidence” - at least half of which is actually in the article, showing again he didn’t read it. The other half are junk links and references and not a single major cited journal article that is not discussed in the article. He even references a Jim Stewart paper, also in the article, despite Jim’s clear position that Ireland is a tax haven???

4. And realizing that he has shown that he hasn’t read the article, and doesn’t understand this topic, or wants to understand, it as he has decided the answer, makes an very personal allegation of bad faith and anti-Irishness, which is BS, and I am Irish.

Irish people, of which I am one, have to remove the reality distortion field around the tax haven issue. The bogus arguments that are concocted to try and refute it are embarrassing. This objectors comments and approach are embarrassing. This article has a ton of good quality facts and references on the issue. There is nothing in the lede that is not established as a fact in the body (except maybe the last line in lede). Just listing out a table of the 10 most cited research on tax havens and what they call Ireland would solve this issue on a short paragraph. However an editor has gone to impressive lengths to expand the fact base around several aspects of the issue. The only source of bias is the objectors POV, which is also needlessly offensive. Sorry for the anonymity.31.187.2.14 (talk) 20:02, 27 August 2018 (UTC)

(return to discussion by Britishfinance)

Hi, britishfinance here again and sorry for the delay in responding. I didn't have time and I wanted to go through all the proposed links above. I have added a letter to each link above so that I can reference them below without having to repeat them:

A. Diarmuid Ferriter's article is there under "Sources", "The term tax haven has been used by the Irish mainstream media...". Obviously, he is not a tax person, but he is an major chronicler himself and thus the fact that he is noting the issue is relevant. His own quotes would indicate that he does not believe the Dept of Finance? ("The Department of Finance can persist in denying what seems obvious to the rest of us eejits"), however I did not want to add such quotes as it is non-academic (in the tax sense).

B. There are loads of good quality Irish Times articles on this subject which basically say something like "we need to be careful here, as we are being called out"; the best one is the IT article that is cited right after the Diarmuid Ferriter article, which was an IT Editorial and I think captures the issue best. It is very similar to your one but has more content. Again, as the IT is not an academic source (they are not tax experts), there is no point referencing them more than just to say that it is being discussed in Ireland.

C. This article is also the under "Rebuttals", "Hines-Rice 1994", "The Irish State criticises academic studies estimating...". It is important that the formal State rebuttals like this one are captured in the article, which it is, and then discussed, which it also is.

D. I considered Peter Vale's article but it is a poor quality article and he is making flatly wrong assertions that are not even re-stated even by the Irish State (e.g. Switzerland has an enormous tax treaty network; the Cayman Islands, Gibralter, and Guernsey signed FACTA; even the OECD don't require "substance" in their definition of a tax haven etc.). There would have to be a separate sub-section under "Rebuttals" just on this article as it is so broad, and wrong, which might seem a bit petty, just to focus on one guy or single him out? However, I am open to this if you think it should be done? The article (under "Rebuttals", "OECD 1998 definition") has better rebuttals by Tom Maguire (head of tax Deloitte) [ref 174] and Suzanne Kelly (past head of Institute of tax and one of the best tax people in Ireland) [ref 175] - again, both quote the OECD term.

E. Moscovi quote is a good one and I am putting it in under "Rebuttals" - "EU Tax haven lists". It doesn't really change the summary as it states that Ireland is not on the EU tax haven list, and this list has credibility issues as noted in the article, however, I think it is a good fact to reference. Also, Moscovi has called Ireland a tax "black hole" as well ???? I have another similar quote from the OECD chief saying the same thing under the OECD section "Ireland is not a tax haven" (ref no. 183), so thanks for that.

F & G These are Irish State publications, or Irish State ministers, refuting the label, however, there are several alternatives quotes in the "Rebuttals" section which were preferred as they are more specific as to the reasons why Ireland is not a tax haven. If you felt that there was a type/class of Irish State rebuttal, that is not covered under the "Rebuttals" section, then we should DEFINITELY include a new sub-section for that and discuss it.

H & I The article has the Pascal Donohue reference, under "Rebuttals", "OCED 1998 definition", as he specified the reasons (e.g. Ireland does not meet the OECD definition), and is a better quote than Leo Vardakars (which is same). Again, same as per F & G, if there is a type/class of Irish State rebuttal missing, we should include.

J. This report is covered a lot "Rebuttals", "Hines-Rice 1994", and the report's conclusions are even listed out fully in the text as they appear in the report. This report is not academic. It was written by Gary Tobin (Department of Finance Ireland) and Keith Walsh (Department of Irish Revenue). No international academic journal would touch this article, so they got it into the ESRI quarterly (which Irish State funded). It's the main conclusion, that Ireland is not a tax haven as it does not meet the OECD definition is covered in detail in the article. However, this report was a low-point in Irish State rebuttals of the label as they tried to make out that all the academic research was from one "obscure" paper which was out of date (the Hines Rice 1994 paper was one of the most cited papers in the US Council of Economic Advisors October 2017 report on the economic rationale for the US TCJA). I could have added some references to some very harsh comments on the integrity of this article however it was more important to show its conclusions and discuss them.

K. Jim Stewart's MNC paper is quoted in the article under "Sources", item iv (reference 23.). Jim Stewart is probably the most vocal academic figure in Ireland calling Ireland a tax haven ?? He is hated by the Dept of Finance and several Irish tax experts (links can be provided). His analysis is very good, and I have listed him out of respect for this. However I could have listed a lot more from Jim which is much harder on Ireland as a tax haven (especially the Captured State material), but I wanted to keep the academic sources to the biggest names, in the biggest academic journals/books, given the subject matter.

L. Not sure what this source is good for - it is the Irish Revenue rules on residency - you could easily quote back the findings of the EU Commission 30.08.16 report on Apple (all 130 pages) to see how the Irish Revenue apply their own rules ?? (I digress, sorry).

Some other points:

M. You say that non-Irish sources are thin on the ground but this is not true. The "Sources" section lists major academic papers, published in the biggest academic financial journals in the world, analyzing Ireland as a tax haven. The biggest academics in tax research have been listing Ireland as a tax haven from a quarter of a century.

N. You say that Ireland is a "tax conduit", however, the article under "Sources" lists that Ireland has also been labeled a Conduit OFC (a defined term). However, the tools of "profit shifting" were understood academically since the early 1990s (actually, James R. Hines is arguably a co-founder of this term). The nuances between Conduit OFCs and Sink OFCs were understood long before they became defined academic terms. The biggest academics label Ireland BOTH a tax haven AND a conduit OFC. Being a conduit OFC, however, does not stop you from being a tax haven, and therefore there is no obfuscation about it. There are also many links in the article to the major Conduit and Sink OFC CORPNET study.

(in summary)

I hope that the above reply helps. Your citing of Jim Stewart implies that you are not an Irish tax person, which is completely fine. The article is written to use high-quality academic sources as much as possible, but also to do in a way to help non-experts navigate this topic (a major WP objective in all cases). Therefore, if you still felt unhappy about the article having read my responses above, I would love to continue the discourse here? Nothing in the lede of this article should summarise anything that is not factually demonstrated in the main body. But also, the body should also capture all the main high-quality facts about this topic. If this is violated, let's discuss again.

Finally, nothing I have written in this is hopefully "anti-Irish". That is a harsh allegation to make and not consistent with WP unless you have specific text in mind?

I hope you can see that a lot of effort was put into building proper and good quality facts on this topic (not just references to newspapers or random material etc.). Having done the exercise, I can see the general Irish media discourse on this issue lacks many facts that are well understood outside of Ireland (e.g. James R. Hines Jr. is not an obscure figure in US taxation - it is one of its leaders today), and different arguments are being presented as accepted facts.

Hope this helps, and sorry for taking so long to come back.Britishfinance (talk) 14:25, 2 September 2018 (UTC)


 * Hi, I have also inserted a new section called "Context" at the top that might also help. I think the problem is that "Sources"-"Evidence"-"Rebuttals" leaves one feeling that Ireland is definitely a tax haven (it is hard to deny this part), however, "Political Compromises" gets to the heart that yes, Ireland might be a haven, but the U.S. needs Ireland to address major structural problems in its corporate tax code, and the OECD-EU are willing to facilitate the U.S. in doing this (and the EU earns taxes from the US, via Ireland, from being accomodating with Ireland).  Of course, this gets to another major issue, which is whether the TCJA will change the US attitude to Ireland (or maybe even amplify it)? Britishfinance (talk) 15:18, 3 September 2018 (UTC)


 * I have unflagged given the above answers; if there are new concerns/material, please do re-flag the article but specify reasons on talk page so they can be discussed etc. (or flag will be removed immediately). I think the above discussion was useful to log for editors to read regardless (anthough the anti-Irish part is not appreciated).Britishfinance (talk) 19:28, 3 September 2018 (UTC)


 * Excellent response User:Britishfinance — Preceding unsigned comment added by 31.187.0.241 (talk) 12:24, 29 January 2019 (UTC)
 * thanks, I tried my best. Britishfinance (talk) 14:27, 29 January 2019 (UTC)

Question about citation?
"This Irish "employment tax" requirement for use of BEPS tools, and its fulfilment via foreign work-visas, is a driver of Dublin's housing crisis."

This is followed with this as a citation: https://www.irishtimes.com/business/economy/is-ireland-s-booming-economy-just-a-illusion-1.3444645

Can someone explain how the article validates the statement above? — Preceding unsigned comment added by 141.0.151.162 (talk) 08:50, 16 August 2018 (UTC)
 * the article says that despite ireland being at full employment there are no wage increases and the multinationals are filling jobs with foreign workers. if you are 25-35 in ireland and renting you have no future. foreign investors are buying up and paying no tax.  i know this because I am living it. in my parents ireland this situation would have make big wage increases so I can pay rents or buy house. but if i walk they can replace me in the morning from out of ireland at same wage, and they do. article is spot on, and there are many more like it.  — Preceding unsigned comment added by 31.187.0.185 (talk) 14:32, 16 August 2018 (UTC)

Great article
Just want to note my appreciation for this article - it has been a very helpful source of sources for me on the subject. Would love to see equivalent for Luxembourg and Singapore? — Preceding unsigned comment added by 31.187.0.241 (talk) 12:24, 29 January 2019 (UTC)
 * Singapore is the AsiaPac HQ for Apple, Facebook, and Google (and many other U.S. tech/life sciences corporates), which will indicate how powerful its platform is. Singapore as a tax haven is a potential project in this area but unfortunately, Singapore is very (very) secretive.  here are no EU or US investigations that have forced disclosure like in Ireland, so searchable/verifiable sources are very hard to find. An article on Singapore's corporate tax system would require quoting from more primary sources (e.g. Singapore tax legislation), which runs into OR issues. Britishfinance (talk) 14:26, 29 January 2019 (UTC)

Mention on Quora of this article as a useful source
From Quora: Is Ireland a Tax Haven?. A comment from Quora that I think this article was created for: "See Ireland as a tax haven - Wikipedia for lots of information about the reasons for/against categorising Ireland as a tax haven.". Britishfinance (talk) 13:57, 1 March 2019 (UTC)

"Ireland has failed to win Brexit financial services firms.". Is this correct?
https://www.rte.ie/news/business/2019/0320/1037475-dublin-still-most-popular-choice-for-financial-services/


 * The EY Funds Tracker tracks the movement of legal fund wrappers (not people); the two 2017 surveys that tracked the movement of people (Bloomberg and EU FDI) ranked Ireland poorly. Irish media do quote the EY Funds Tracker and say that it is "Companies relocating to Ireland from Brexit", but it is really the ongoing movement of legal structures around Europe; most of which has been moving to Ireland, Luxembourg and the Netherlands for the last 10 years as they are the leading tax havens in Europe (so it speaks well to Ireland's ranking as a tax haven, but says little about Brexit people movement in financial services).  Goldman Sachs has recently done a report listing all the movement of London-based banking/insurance/asset mgt financial services people (which is mostly all to Frankfurt and Paris, and some to Lux), but I cannot find a 3rd party WP:RS reference to it so that could be used in this article?? Britishfinance (talk) 11:45, 20 March 2019 (UTC)


 * I should note that while most of the "planned" relocation of financial services people due to Brexit has not been to Ireland, a dis-orderly Brexit could change that. We could see London firms that had expected Brexit to work out in a particular way, being forced to set up even an interim office in Dublin. Unpredictable times! Britishfinance (talk) 11:48, 20 March 2019 (UTC)

"Captured state"
This section caught my eye, so I selected it for analysis. In the context of the section on "captured state", there seems to be over-reliance on the Nicholas Shaxson/Tax Justice Network source. There seems to be a consistent issue with how the assertions made in this section do not correspond with the cited sources. The term "captured state" itself is a pejorative term that refers to systemic political corruption in which private interests significantly influence a state's decision-making processes to their own advantage (see state capture), and the only place where I have seen it being extensively used in the context of international taxation is on Tax Justice Network's website. Going by the sources presented in this section, it does not seem suitable to include their claims in Wikipedia's voice, as they appear to be outliers rather than mainstream views. The need to have a section with this title ought to be considered as well.

1. There is evidence Ireland meets the captured state criteria for tax havens.

In this case, the Irish Times source does not discuss Ireland as a "captured state", but the suspected use of IFSC for large cash influxes into Russian banks and oil companies. The second article is an advocacy piece authored by Nicholas Shaxson for Tax Justice Network (TJN), an organization dedicated to tax advocacy. Nicholas Shaxson is an investigative journalist who works as a part-time writer and researcher for TJN. His WP biography does not suggest any specific academic or technical expertise in the field of finance, economics or international taxation.

Following this sentence, the remainder of the first paragraph delves into an assortment of "facts" or incidents that are patched together under the "captured state" header, insinuating something but not really establishing a link between the the fact presented and "captured state".

2. When the EU investigated Apple in Ireland in 2016 they found private tax rulings from the Irish Revenue giving Apple a tax rate of 0.005% on +€100 billion of profits.

While the Europa.eu source refers to an effective rate of taxation of 0.005%, it does not speak of "+€100 billion of profits". I went through the article from the International Trade Journal as well, hosted on Taylor & Francis, but could not find any reference "+€100 billion of profits" either.

3. When the Irish Finance Minister Michael Noonan was alerted by an Irish MEP in 2016 to a new Irish BEPS tool to replace the double Irish (called the single malt), he was told to "put on the green jersey".

This assertion is entirely based on a WP:PRIMARY source.

4. When Apple executed the largest BEPS transaction in history in Q1 2015 (see "leprechaun economics"), the Central Statistics Office suppressed data to hide Apple's identity.

Nowhere does the cited source say that the CSO "suppressed data to hide Apple's identity". Instead, it claims: 'Given that the changes were attributable to the actions of just a handful of multinationals, the CSO was understandably cagey about the whole thing and suppressed some components of the normal data release in order to “protect the confidentiality of the contributing companies.”'

5. When it was discovered in 2016 that U.S. distressed debt funds abused Section 110 SPVs to shield €80 billion in Irish loan balances from Irish taxes, the Irish State did not investigate or prosecute (see Section 110 abuse).

Citation needed.

6. In February 2018, the Central Bank of Ireland, who regulates Section 110 SPVs, upgraded the little used L-QIAIF tax-free regime, which has stronger privacy from public scrutiny.

It appears to me that the source says that in January 2017, the Central Bank of Ireland expanded the range of activities available to L-QIAFS. It says nothing about "stronger privacy from public scrutiny".

7. In June 2018, U.S. distressed debt funds transferred €55 billion of Irish assets (25% of Irish GNI*), out of Section 110 SPVs and into L–QIAIFs.

This source says nothing about US distressed debt funds shifting their funds into L-QIAFS.

8. The June 2017 OECD Anti-BEPS MLI was signed by 70 jurisdictions. The corporate tax havens, including Ireland, opted out of the key Article 12.

The terms "corporate tax haven" or "tax haven" does not appear in the article. In fact, the source says the following: "Other jurisdictions that have not signed up to the measure include the Isle of Man, Mauritius, Jersey, Malta, Luxembourg, Switzerland, Germany, Greece, Italy, Portugal and the United Kingdom. Countries that have adopted the measure include France, Norway, Turkey, Spain, Japan, Argentina and Nigeria." Of these, Germany, Greece, Italy, Portugal and the United Kingdom, who did not accept Article 12 (on commissionaire arrangements) along with Ireland, are not generally considered to be tax havens.

9. Tax haven investigator Nicholas Shaxson documents how Ireland's captured state uses a complex, and "siloed", network of Irish privacy and Irish data protection laws to navigate around the fact that most of its tax tools are OECD–whitelisted, and therefore must be transparent to some State entity.

As far as I can see, none of the sources purport to say what has been asserted above, and especially not Matheson or John Gulliver. The last link to treasureislands.org is to a blog by Nicholas Shaxson, but not to a specific citation to his work making that claim.

10. For example, Irish QIAIFs (and L–QIAIFs) are regulated by the Central Bank of Ireland and must provide the Bank with details of their financials. However, the 1942 Central Bank Secrecy Act prevents the Central Bank from sending this data to the Revenue Commissioners.

Neither does this source make any direct claim regarding Irish QIAIFs or L-QIAIFs, nor does it make any direct reference to the issue of Central Bank being prevented from sending data to Revenue Commissioners. At best, this is original synthesis.

11. Similarly, the Central Statistics Office (Ireland) stated it had to restrict its public data release in 2016–17 to protect the Apple's identity during its 2015 BEPS action, because the 1993 Central Statistics Act prohibits use of economic data for revealing such activities.

The citation reference is to the "Information for Data Providers" page maintained on the website of Central Statistics Office. Aside from being a WP:PRIMARY source, there is nothing in this page that alludes to the assertion above.

12. When the EU Commission fined Apple €13 billion for illegal State aid in 2016, there were no official records of any discussion of the tax deal given to Apple outside of the Irish Revenue Commissioners because such data is also protected.

This appears to be a correct representation of the source, but I am able to access only the preview, as the article is heavily paywalled.

13. When Tim Cook stated in 2016 that Apple was the largest tax-payer in Ireland, the Irish Revenue Commissioners quoted Section 815A of the 1997 Tax Acts that prevents them disclosing such information, even to members of Dail Eireann, or the Irish Department of Finance (despite the fact that Apple is circa one-fifth of Ireland's GDP).

The portion at the end ("despite the fact that Apple is circa one-fifth of Ireland's GDP") is not represented in this particular article, and therefore seems to be either original research or original synthesis.

14. Commentators note the "plausible deniability" provided by Irish privacy and data protection laws, that enable the State to function as a tax haven while maintaining OECD compliance. They ensure the State entity regulating each tax tool are "siloed" from the Irish Revenue, and public scrutiny via FOI laws.

The terms "plausible deniability" does not appear in any of the three sources. There are no references to "Irish privacy and data protection laws". The term "silo" or "siloed" does not appear once in the sources, and none of the sources say that regulators are insulated from public scrutiny through freedom of information laws. Aside from Shaxson, the other author is a UN official called "Philip Alston" with a human rights background and no expertise in finance, economics or taxation.

15. In February 2019, The Guardian reported on leaked Facebook internal reports revealing the influence Facebook had on the Irish State, to which Cambridge University academic John Naughton stated: "the leak was “explosive” in the way it revealed the “vassalage” of the Irish state to the big tech companies".

This article has nothing to do with Ireland as a tax haven.

— Nearly Headless Nick   {c}  01:37, 17 April 2019 (UTC)


 * Thanks, and it is clear some study is required here. I'm no expert, but I have seen three of these tax-related articles over time, and have been looking harder at a couple since yesterday's episode, and the above apparent mis-alignments seem out of line with Britishfinance's usual meticulous approach, but of course there have probably been diverse hands at work. This article is of a rather specific type, and there is a risk of opinion shading in (and it is hard to assess, as while there should probably be such articles for about 10 countries and groups of countries, there seem be be only two - missing would be similar ones for the Netherlands, Switzerland, the UK and British Crown Dependencies such as the Isle of Man and the Channel Islands, plus maybe Singapore, and then plus the Caymans, BVI, etc., for "terminal" and personal tax.SeoR (talk) 08:00, 17 April 2019 (UTC)
 * . I was going to try Singapore next which is a very interesting case; however these articles take a long time to do and gather the refs. People have dont Panama as a tax haven and the United States as a tax haven, but I am not sure they are any good. There is a lot of academic research and books on these topics (per refs in this article), but they are complex subjects. Perhaps the issue is that the people who have the subject-level skill to start constructing them, aren't willing to donote their time to WP to do them. Britishfinance (talk) 09:16, 17 April 2019 (UTC)


 * . Sorry, but I don't have the time to go through the above in detail now but will get to it.  Can I add my response below each section, or do you want to number the specific points and I will respond to each below (I remember this was a issue you were not happy with on Articles for deletion/Vidyut Kale)?  I think that in cases above the wording might need to be changed. For example, statements like the last one from Facebook where an Irish Cambridge academic John Naughton uses "vassalage" instead of "captured state" in relation to Facebook in Ireland.  I don't think that it matters in this section that he does no refer to a "tax haven", Naughton is showing that Facebook have exception control over Ireland, which is the point?  Similarly, in the second last one of "plausible deniability", I do believe that Nicholas Shaxson used this term in his book (been a long time since I read it), and the other references from the UN Commissioner are not unsupportative of this view (e.g. he might not also use the excat term, but close)?  Anyway, very happy to go through this and re-write to get tighter to the references used.  I have only recently started using the Harvard-citation style (see Tax inversion), which I wish I had started off with in WP.  However, this section could be a good place to apply and there are at least three good books (including Nicholas Shaxson's), that discuss the topic in a lot of detail.  Anyway, as you will have seen in my past discussion in the archived talk page at: Talk:Ireland as a tax haven/Archive 1, I am willing to put the time in an help out here. thanks. Britishfinance (talk) 09:07, 17 April 2019 (UTC)

Response to the above comments (using same numbering).

1. Nicholas Shaxson is notable enough to have his own WP article on him, and has written (as referenced earlier in this article) one of the most referenced books on tax havens (in which he also uses the term "Captured State" for Ireland). In fact his book is also a WP article: Treasure Islands: Tax Havens and the Men Who Stole the World. The reference used has Shaxson stating But on another level this is an Irish version of a phenomenon we’ve encountered across the tax haven world: the state ‘captured’ by offshore financial services.. That is what he said. The second reference is the former Deputy Gov. of the Central Bank of Ireland publically stating that the Irish government is taking risks with various vehicles for foreign clients that it does not understand, which, semantics aside, is "captured state" type activity.

2. I didn't link to the full EU report that does include the Euro 100bn figure, just their summary press release that I can see they have not mentioned it. It should be apparent that Ireland's tax rate of 12.5% versus Apple's tax rate of 0.005% giving a 13bn fine (excluding interest penalties) equates to a 100bn of untaxed profits. However the full EU report goes give the calculation and I can insert that (it is in the article: EU illegal State aid case against Apple in Ireland).

3. This reference is not from the person who said it, it is from the official record of statements made in the Irish parliment that is seperately recorded by Irish public servants. It is a better source than an Irish newspaper recording that he said it. I think the issues of PRIMARY sourcing are not a problem here. This was a very important and public statement that was made in the Irish parliment, and is also very important in how the Irish Finance Minister reacted on being warned of tax improprietry. Again, "captured state" activity.

4. My mistake, this is the wrong reference. The CSO themselves helpfully clarified that they had suppressed the source (and data), and issued a statement to this effect. As a consequence of the overall scale of these additions, elements of the results that would previously been published are now suppressed to protect the confidentiality of the contributing companies, in accordance with the Statistics Act 1993.. Again, I do think that this act was important and is not the act of an open and transparent system.

5. I didn't add a citation on this one but instead gave a link to a seperate sub-section in another article on this affair (see Section 110 abuse). In this sub-section it covers that no prosecutation was made. I think this is the right way to proceed on this (or should I start importing references from the linked article - I already have a lot of refs in this article)?

6. Again, as per 5, there is a whole seperate article on QIAIFs that shows with references that they don't file public accounts (where are Section 110 SPVs do). Do I really need to import references from the QIAIFs, or is that not overkill? The information is there on the QIAIF article for those who want it?

7. In Ireland, the terms distressed debt and vulture funds are used interchangeably. The reference calls them vulture funds. The best souce on the 55bn move was a large article by the Sunday Business Post covering it (vehicles used, figures, comments from experts etc.), here. Unfortunately it is fully behind a paywall (not even a preview). The Irish Times did refer to the Post article which may be helpful here

8. The statement should be that the main corporate tax havens all opted out of it (which is true). Some non-corporate tax havens also opted out, but their reasons a more complex (although, they do link back to their own "home" multinationals using corporate tax havens; however I cannot find a public source on this which would be suitable for WP). However, my real point here was the quote that follows which is from the Irish Times and makes that point that Ireland opted out because of Baker McK's requests, which again, goes back to being a captured state. That is the Irish Times raising the concern.

9. I have his book in which he makes these statemenets clear. I avoided using "books" as references in my WP tax articles as they can't always be referenced easily. But I realise that I am not doing the subject matter proper justice with other refs that don't make the exact point of the books. I will fix that and use the books.

10. The Central Bank of Ireland are the sole regulator for QIAIFs and L-QIAIFs (I have mentioned that in their individual WP articles, but I can repeat here). As it stands, the 1942 Central Bank Act (which the refs covers), doesn't allow Central Bank data to be shared. That is not OR, it is the reality, and the Irish Times articles makes a decent reference to it? The Irish Times reference does not cover QIAIFs but I don't need it to. This secrecy of the 1942 Act are well understood (this is not a controversial or disputed point in Ireland; although the Act is), so if you still felt that it needed more, I could try and find additionaly references on it?

11. This is the same issue in Point 4. in which the CSO clarified that under the 1993 Act they were bound to suppress the Apple data As a consequence of the overall scale of these additions, elements of the results that would previously been published are now suppressed to protect the confidentiality of the contributing companies, in accordance with the Statistics Act 1993. It may be PRIMARY, but the not all primary is wrong, and I think it is fine to have the CSO themselves quoting the Act directly as tying their hands in terms of releasing information; which again, goes to the issue of not being transparent.

12. The paywall is a pity, but I hope you will appreciate the lengths I have gone to use easily checkable references? I have included the quote form Bertie A in the reference, but unfortunately I can't do anything about the paywall. Given that Bertie was the ex. head of Ireland, it is a great reference? And again, goes to the issues that Shaxson discussed in his book about how Ireland "silos" its systems to avoid such disclosures and give plausible deniability.

13. Fair spot on that. Obviously given that Ireland's 2015 GDP rose by 34% (on final restatement - see Leprechaun economics) from Apple's BEPS transaction in Ireland (which was confirmed by Seamus Coffey, the guy who the Irish State got to review its entire tax code in 2016), then by basic math implication Apple is more than one-fifth of Ireland's GDP, however, I should be backing that up with a seperate independent ref, rather than expecting the reader to make the calculations.

14. Same point per earlier on Shaxson, I need to just reference his book directly where he used these terms. I have also have another book Tax Havens: How Globalization Really Works by Ronen Palan and Richard Murphy (both with their own WP articles), that I mention earlier (under "Source of labels") which use the same terms. Seperately, Philip Alston is a very senior figure and academic (with his own WP article); he made the statements publically A UNITED Nations official has launched a scathing attack on Ireland over its corporation tax regime. and the references covered them. They are WP:RS and they are notable regarding this section.

15. I think we are splitting hairs here. John Naughton is another senior notable academic in Cambridge (and Irish), who explicitly uses the term "vassalage" in relation to Ireland and Facebook. He doesn't need to use the term tax haven. He is literally stating that the Irish State is subserviant to the needs of Facebook in Ireland. That is a notable person claiming Ireland is acting as a captured state for a major US corporations (who has been publically highlighted as using the Double Irish etc.).

. Having gone through your 15 points and answered most of them (I can fix others), I do think that you might re-consider whether this is evidence of NPOV issues. I have used sources who are notable enough to have their own WP articles (and for some, even their on WP articles on their books). When a source is potentially PRIMARY, I don't it it is a problem, and in fact given that they are Government-related sources, are even stronger. Perhaps could also chime in here, but I hope I get some fairness here from you on this. Wikipedia is not a peer-reviewed journal, however, I think I have done a decent job keeping to the main facts and using good refereneces (nothwithstanding that I will need to use Shaxson's and Palan's books). I have not stated "Ireland is a captured state", but I stated that "there is evidence". And I do think the above bears that out. Britishfinance (talk) 16:10, 18 April 2019 (UTC)


 * Thanks, and I'd be happy to have a look. I hope Sir Nicholas de Mimsy-Porpington / Nearly Headless Nick has some time to look too.SeoR (talk) 13:38, 19 April 2019 (UTC)

Britain as a tax haven
This is a hard article on little ol' Ireland, so how about one on The UK as a tax haven given that the Guardian today published an article which said that:

- the UK and crown dependencies, etc., form by far the world’s greatest enabler of corporate tax avoidance

- British territories and dependencies constitute 4/10 of places that have done the most to “proliferate corporate tax avoidance" and the UK itself is #13

-- #1-3: British Virgin Islands (BVI), Bermuda, the Cayman Islands – all British overseas territories

-- #7: Jersey (Crown dependency), behind the Netherlands, Switzerland and Luxembourg, and followed by Singapore, the Bahamas and Hong Kong

- No Ireland! Thanks.178.176.23.66 (talk) 13:48, 29 May 2019 (UTC)


 * That is a Tax Justice Network (TJN) report which is poor in tax haven research terms. There is some TJN material quoted in WP articles but most of it is where it is linked to a notable outside tax figure or tax academic (most of the best TJN work was where they made such partnerships).  The latest TJN report is effectively qualitative (all academic work is now quantitative), and just poor math; it ranks the US as the largest overall corporate tax haven, even though no corporate has moved to the US to reduce taxes (tax inversion).  A lot of NGO research on tax havens is not of encyclopedic quality.
 * HOWEVER, WP articles chronicle the UK's position at the heart of a nexus of tax havens (e.g. Tax haven), and its own rise as a tax haven post 2009-12 (e.g. Conduit and Sink OFCs, Tax inversion). The UK changed its tax code in 2009-12 and copied almost every Irish tax tool. It was racing up the academic league tables of tax havens (e.g. Tax haven).  Things stalled since Brexit, and the UK even restricted some of its tools, however, this could have been for Brexit talks where the UK might have been keen to show it is not a tax haven to the EU.
 * Certainly, the UK as a tax haven would make a good WP article, however, I think it will have to wait until Brexit is resolved one way or another for it to become a "stable" article; and not subject to material re-writes. It would be a more complex undertaking for various reasons but I believe would be interesting to readers. Will come back to it. Britishfinance (talk) 09:43, 30 May 2019 (UTC)

Tone and Title
This page seems to be more critical of the Irish government than for example - this page on Nazi Germany is of the German authorities of that time. Overall there doesn't seem to be any evidence provided at all anywhere on the page that Ireland it a tax haven for Income tax, VAT/Sales tax, CGT, CAT/Inheritance tax, environmental taxes or stamp duty (which make up the majority of the Irish tax take). It purely refers to shifting of Corporation tax. If this is the case then should the title really be changed to Ireland as a corporate tax haven?

The key points that I can take from the article are


 * Nicholas Shaxson is a demi-god due to the volume of references he has
 * Ireland is a bad place and the government are stealing from the rest of the world

Financefactz (talk) 15:25, 9 October 2019 (UTC)Financefactz


 * In an article with over 305 references, Nicholas Shaxson (who is a noted tax haven author on WP with his own BLP, and whose books on tax also have their own WP articles, including Treasure Islands: Tax Havens and the Men Who Stole the World, has 3 references). Your "Nazi Germany" comparison, and your attempt to confuse tax havens with VAT/Stamp Duty, shows that you are here for a different purpose than to discuss the topic.  There is plenty of fully referenced material in the section on "Labels" which references some of the most noted experts on Tax Havens in the world, as well as other noted sources, on the specific subject of Ireland as a Tax Haven. Britishfinance (talk) 15:44, 9 October 2019 (UTC)

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Whether Ireland did or did not benefit from significant post-Brexit job moves (in Finance)
A recent edit added an update that (after an inarguably poor initial phase, for various reasons) Ireland eventually gained a decent number of financial services relocations. Two solid (but not outstanding or academic) sources were provided. The only thing is that the reported versions, at least, did not have a clear statement on jobs moved, only on firms (and a move of a firm or unit can involve 1-2 people with a brass plate, or hundreds). A further edit by an IP today (which IP did some other broadly useful editing) partly reversed the above, notably from the lede. Any additional perspective welcome...

Claim that eventually Ireland did benefit:

Source 1 - Dublin is Top Brexit Relocation Spot for Finance Firms, EY Finds / Luxembourg second-most popular place, followed by Frankfurt (Three dozen financial services firms are considering moving some U.K. operations to the Irish capital, or have already done so, the review found. Luxembourg is second, attracting 29 companies in total, followed by Frankfurt, which has drawn 23. Twenty businesses are moving business to Paris, according to EY’s survey of public statements by 222 firms through February. ... EY Financial Services Brexit Tracker: Note: Data derived from public statements made by 222 financial services firm between June 24, 2016 and Feb. 28, 2021) Source 2 - New Financial (a think tank): More than 400 financial firms in Britain have shifted activities, staff, ... to hubs in the European Union due to Brexit, ... Dublin has emerged as the biggest beneficiary with 135 relocations, followed by Paris with 102, Luxembourg 95, Frankfurt 63, and Amsterdam 48. "We expect Frankfurt will be the 'winner' in terms of assets in the longer-term, and that Paris will ultimately be the biggest beneficiary in terms of jobs," the study said.

Wording applied today: Ireland secured no Brexit players from UK financial services (e.g. Goldman, JPM, Merrill), not even a mid-sized US/Japanese player

SeoR (talk) 23:06, 24 October 2021 (UTC)


 * I think Brexit was not the win Ireland expected in financial services. None of the main non-UK financial services players in London came to Ireland.  Only Barclays in Ireland expanded their platform, but they were in Ireland already.  All the main US players went to Paris and Frankfurt.  The US insurers went to Luxembourg, and traders to Amsterdam and Paris/Frankfurt.  Barclays used to run a Brexit tracker that tracked all the main financial services jobs and assets and Dublin featured well down the table.  The EY report was misquoted by Irish media.  The EY report showed that Frankfurt got most of the assets, and Paris most of the jobs, with Amsterdam a strong second/third.  The EY report showed that Ireland got a lot of shell-company type switches last year, but that is because Ireland was the only EU player to enable London based firms to move shell companies easily - no other EU player would allow this.  I think you have to take some of these Irish media stories with a healthy skepticism - they feel promotional.  If I have time, I will try to update this properly in the article, which I do think deserves proper treatment as it is quite accurate and researched. 46.7.85.200 (talk) 00:19, 25 October 2021 (UTC)
 * I personally think the EU bullied the main US banks into using Paris or Frankfurt, but I think Ireland would have been disappointed to do so poorly in insurance given its long-standing passporting platforms in this area. The real winner of Brexit in financial services was Amsterdam, which has now become Europe's largest trading hub for many assets and is well on its way to passing London in most trading sectors, with swaps likely to be the final nail in London's coffin in 2023/2024.  There are few trading hubs in Ireland.  The Irish Brexit financial services jobs are really legal jobs driven by setting up financial services shell operations, which is a specialty of Ireland.  The original article was correct, Dublin attracted few of the "talent" jobs in financial services from Brexit like investment/commercial banking or trading. 46.7.85.200 (talk) 00:28, 25 October 2021 (UTC)