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Microsoft Reduces Irish Corporate Tax Liability To Less Than 10%
by Jason Gorringe, Tax-News.com, London

12 July 2006

Microsoft's Irish subsidiary, which continues to be the country's most profitable company, last year reduced its effective tax rate in Ireland to below 10%, according to a report in the Irish media.

Citing accounts filed with the Companies Office, the Irish Independent reported yesterday that Microsoft Ireland increased its sales by EUR225 ($287 million) last year, with turnover in the year to the end of June 2005 reaching EUR8.3 billion.

The report stated that the company paid EUR237 million to the Irish state in taxes last year - slightly lower than in the previous year - and paid an effective tax rate of 9.9% by taking advantage of manufacturing tax relief and adjustments from the previous year. The headline corporate tax rate in Ireland is 12.5%.

Ireland's low rate of corporate tax has been successful in attracting large numbers of foreign companies, particularly from America. However, the US government has grown concerned that American firms are setting up Irish subsidiaries to help avoid domestic taxes.

Speaking before the Senate Finance Committee last February, then US Treasury Secretary, John Snow confirmed that the government would be taking action to prevent US multinationals from reducing their tax bills by billions of dollars using subsidiaries located in low tax jurisdictions.

During the hearing, Microsoft was singled out as one company that was taking advantage of Ireland's low corporate tax rate to reduce its overall tax bill. According to reports, last year Microsoft reported $9 billion (or 22% of its gross profits) through its Irish subsidiary.

The US Treasury has pledged to limit the amount by which US tax bills can be reduced in cost-sharing arrangements such as that employed by Microsoft.

A comprehensive report in our Intelligence Report series looking at offshore and onshore corporate structures and their tax implications is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp and a description of the report can be seen at http://www.lowtaxlibrary.com/asp/description_report7.asp

 


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