page_title: International Financial Services Centre
section_title: Technology expansion
hierarchical_section_title: International Financial Services Centre / Technology expansion
caption_attribution_description: English: Feargal O'Rourke and Irish Taoiseach Enda Kenny at a Conference in 2014
context_page_description: The International Financial Services Centre is an area of central Dublin and part of the CBD established in the 1980s as an urban regeneration area and Special Economic Zone on the derelict state owned former port authority lands of the reclaimed North Wall and George's Dock areas of the Dublin Docklands. The term has now morphed into use as a metonym for the Irish financial services industry as well as being used as an address and still being classified as an SEZ.
  It officially began in 1987 as an SEZ on an 11-hectare docklands site in central Dublin, with EU approval to apply a 10% corporate tax rate for "designated financial services activities" on the site. Before the expiry of this EU approval in 2005, the Irish Government legislated to effectively have a national flat rate by reducing the overall Irish corporate tax rate from 32% to 12.5% which was introduced in 2003.
  An additional primary goal of the IFSC was to assist the urban renewal and development programme of the North Wall area as a result of its dereliction following the advent of containerisation in the 1960s.
context_section_description: The 2015 IFSC III phase saw the "financial" IFSC merge with the neighboring Grand Canal Dock and Dublin Docklands areas; comprising major offices of global technology multinationals including Google, Facebook, and Amazon. Since the 2015 expansion, the term "International Services Centre" (ISC) is sometimes used.
  Some of the biggest offices in the IFSC are the law firms (e.g. Matheson, A&L Goodbody, McCann Fitzgerald, and William Fry), and accounting firms (e.g. PwC, KPMG, Deloitte, and Ernst & Young), who advise both the financial multinationals and technology multinationals, operating in the Greater Dublin Area.
  The legal structures created by IFSC law and accounting firms for securitization (e.g. Section 110 SPVs, and QIAIFs), became important to the tax structuring of US technology firms in the IFSC. Such structures are part of a suite of base erosion and profit shifting (BEPS) tools that enable US technology firms to achieve an effective tax rate (ETR) of under 4% on all non-US global profits shifted to Ireland (see here). PwC Ireland managing partner, Feargal O'Rourke, was credited as creating the Double Irish BEPS tool, while Matheson have also been identified an important developer of US tax structures in Ireland.
  With the closure of the Double Irish arrangement in 2020, the most important BEPS tool in the IFSC is the Capital Allowances for Intangible Assets (CAIA) BEPS tool. Apple used the CAIA BEPS tool in Q1 2015 to execute the largest BEPS action in history, causing the Leprechaun economics revision of Irish GDP data.
  IFSC tax law firms market the sub–2.5% Irish effective tax rates that the CAIA BEPS tool can deliver for technology multinationals in the IFSC, on all their worldwide income that is shifted to Ireland. In 2018, the European Parliament GUE/NGL group called the CAIA tool, the "Green Jersey" BEPS tool.
  The CAIA BEPS tool requires multinationals to create virtual internal intellectual property (IP) assets in offshore locations (e.g. Apple used Jersey). These virtual IP assets are purchased, via intergroup loans, by the Irish subsidiary. The CAIA tool allows the Irish subsidiary to write-off this intergroup purchase against future Irish taxes. An internationally reputable accounting firm is needed to stand over the "valuation" of the virtual group IP asset in the multinational's GAAP accounts.
  "It is hard to imagine any business, under the current [Irish] IP regime, which could not generate substantial intangible assets under Irish GAAP that would be eligible for relief under [the Irish] capital allowances [for intangible assets scheme]." "This puts the attractive 2.5% Irish IP-tax rate within reach of almost any global business that relocates to Ireland."
  — KPMG, "Intellectual Property Tax", 4 December 2017
caption: Former Taoiseach Enda Kenny (l) and PwC (Irl.) Feargal O'Rourke (r)
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