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Another year, another place for Michael Noonan in the Global Tax 50. It is a testament to the success Ireland has had in attracting foreign direct investment through a policy of a low headline corporate tax rate, no controlled foreign company rules, generous R&D relief and a limited transfer pricing regime that the finance minister is again counted as one of the most influential figures in tax around the world. However, this year was not just about the minister lying back and watching the investment flow in. He also had to fight to defend Ireland's reputation as an economy with an open, transparent tax system. In the middle of the year, this effort threatened to blow up in his face when Joaquin Almunia, the outgoing EU competition commissioner and another member of the Global Tax 50, launched an investigation into whether favourable Irish tax rulings for Apple amounted to illegal state aid. The matter is now under the control of Margrethe Vestager, the new competition commissioner, who is also in this list.
In his Budget for 2015, which he delivered in October, Noonan responded to scrutiny of Ireland's international tax arrangements by abandoning the so-called double Irish planning method, which allows companies located in Ireland to transfer royalty payments for the use of intellectual property (IP) via another Irish company to the company owning the IP, usually resident in a tax haven. Companies domiciled in Ireland will now have to be tax resident there too. This change, however, will be phased over six years. Noonan also announced a consultation on the creation of a favourable tax regime for IP, which he called the knowledge development box.
Ireland's 12.5% corporate tax rate will keep it in the firing line of those countries who resent the low tax regime, but it has a doughty defender in the country's finance minister.
The Global Tax 50 2014 |
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Gold tier (ranked in order of influence) 1. Jean-Claude Juncker 2. Pascal Saint-Amans 3. Donato Raponi 4. ICIJ 5. Jacob Lew 6. George Osborne 7. Jun Wang 8. Inverting pharmaceuticals 9. Rished Bade 10. Will Morris Silver tier (in alphabetic order) Joaquín Almunia • Apple • Justice Patrick Boyle • CTPA • Joe Hockey • IMF • Arun Jaitley • Marius Kohl • Tizhong Liao • Kosie Louw • Pierre Moscovici • Michael Noonan • Wolfgang Schäuble • Algirdas Šemeta • Robert Stack Bronze tier (in alphabetic order) Shinzo Abe • Alberto Arenas • Piet Battiau • Monica Bhatia • Bitcoin • Bono • Warren Buffett • ECJ Translators • Eurodad • Hungarian protestors • Indian Special Investigation Team (SIT) • Chris Jordan • Armando Lara Yaffar • McKesson • Patrick Odier • OECD printing facilities • Pier Carlo Padoan • Mariano Rajoy • Najib Razak • Alex Salmond • Skandia • Tax Justice Network • Edward Troup • Margrethe Vestager • Heinz Zourek |