HistoryData
general2016

Effect of Apple's Irish tax structure

July 12, 2016

Apple's BEPS restructuring via Ireland's CAIA tool caused a 26.3% artificial spike in Irish 2015 GDP, exposing Ireland as the world's largest tax haven.

Quick Facts

Year
2016
Category
general

Key Facts

Irish GDP artificial rise (2015)
26.3% (revised to 24.6%)
EU fine on Apple's Double Irish
€13 billion EUR
Irish GDP vs GNI* ratio (2017)
162%
IMF phantom FDI estimate (2019)
60% of Irish foreign direct investment
CSO publication date
12 July 2016
Term coined by
Paul Krugman

By the Numbers

26.3
Irish GDP artificial rise (2015)
13EUR
EU fine on Apple's Double Irish
162
Irish GDP vs GNI* ratio (2017)
60
IMF phantom FDI estimate (2019)

Location

Map of Dublin, IrelandMap of Dublin, IrelandDublin, Ireland

Cause → Event → Consequence

Cause

Apple restructured its tax arrangements in Q1 2015, migrating from the Double Irish hybrid-tax tool — subject to an EU Commission investigation resulting in a €13 billion fine in August 2016 — to Ireland's Capital Allowances for Intangible Assets (CAIA) tool. This shifted vast intangible asset values onto Irish national accounts, representing the largest base erosion and profit shifting action ever recorded.

Event

On 12 July 2016, Ireland's Central Statistics Office published restated 2015 national accounts showing a 26.3% rise in GDP, later revised to 24.6%. Economist Paul Krugman coined the term 'Leprechaun economics' to describe the distortion. The CSO had redacted regular data releases to protect Apple's identity under Irish law, and Apple was only confirmed as the source in Q1 2018.

Consequence

Ireland was blacklisted by Brazil in September 2016, becoming the first major tax haven sanctioned by a G20 economy. Ireland replaced GDP with Modified GNI* in 2017 to better reflect its actual economy. The US and EU introduced BEPS countermeasures in December 2017, and Ireland introduced a reverse tax on intellectual property exits in 2018. Academics concluded Ireland had become the world's largest tax haven.

Timeline Context

Timeline around 201620162013201420152017201820192016 Summer Olympics — Games of the XXXI Olympiad, in Rio de Janeiro, BrazilUEFA Euro 2016 — 15th European association football championshipEurovision Song Contest 2016 — 61st Eurovision Song ContestCopa América Centenario — 2016 edition of the Copa América association football competition2016 Formula One World Championship — 67th season of Formula One motor racingJanuary 2016 — month of 2016Football at the 2016 Summer Olympics — association football played during the 2016 Olympic Summer GamesSwimming at the 2016 Summer Olympics — Swimming on summer Olympic games 2016leprechaun-economics-2016