Recent investigations highlight that multinational corporations continue to shift intellectual property (IP) to Irish subsidiaries to optimize their tax liabilities [1]. This practice involves transferring valuable intangible assets to Ireland, leveraging the country's favorable tax structures [2, 7].
The movement of IP assets significantly impacts pre-tax profits in Ireland, drawing scrutiny from researchers and financial analysts [4, 5]. These strategies enable companies to benefit from Ireland's corporate tax environment, which includes a 12.5% rate for trading income and a 15% minimum tax rate for large multinationals [3, 8].
However, the landscape is evolving. The OECD's Pillar Two rules, implemented in Ireland through the Finance Act (No. 2) 2023, introduce a 15% global minimum tax for multinational groups with annual turnover exceeding EUR750 million [3, 6]. Despite these changes and potential impacts from US tariffs, Ireland remains an attractive hub for international business due to its tax incentives, R&D credits, and strategic location [5, 7, 9].
Companies can also deduct expenses such as consulting, advisory and legal fees related to intellectual property protection [9].
These factors collectively shape Ireland's role in global tax competition and its attractiveness for multinational investments [10, 11, 13].