That is the main defence of recent Irish governments to revelations of tax arrangements used by US multinationals in the past, involving Irish operations as a central part. Well Coca-Cola used the controversial double Irish tax structure, of which a central feature was a company – Atlantic Industries – with its head office and tax residency in the Cayman Islands and a branch in Ireland. Married to the double Irish, this meant a lot of profit earned outside the US was exposed to very little tax. In the Coca-Cola case, the US is holding that the tax is payable in America. Ireland will argue that the tax rules here have changed significantly including the phasing out of the double Irish and other changes.

Source: The Irish Times November 21, 2020 06:22 UTC