Transfer pricing
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Transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transac
Transfer pricing with no external market
Transfer pricing with a competitive external market
Transfer pricing with an imperfect external market
Ireland as a tax haven
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Ireland has been labelled as a corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic tax haven lists, including the § Le
Irish Finance Minister Michael Noonan (2011–2017) told an Irish MEP to "put on the green jersey" when told of a new tax scheme to replace the "Double Irish".
Pierre Moscovici, EU Tax Commissioner, said on the 24 January 2017, the EU did not consider Ireland a tax haven, but on 18 January 2018 said that Ireland was a tax blackhole.
Profitability of U.S. subsidiaries (2015 BEA data)
Irish Taoiseach Enda Kenny (l) PwC (Ireland) Managing Partner Feargal O'Rourke (r), architect of the double Irish BEPS tool