Fiscal incentives, corporate structure and financial aspects of treasury management operations

This paper presents evidence that tax policy affects corporate structure and intra-group financial flows, using a data base of Irish registered firms. How MNC's corporate structure and financial flows react to tax policy is complex. Fiscal incentives play a key role in Irish industrial policy. The paper examines certain financial characteristics of financial subsidiaries (those managing group treasury functions) in Ireland. These characteristics are a tax haven connection, high ratios of revenues to pre-tax profits (in some cases greater than 100%), high intra-group borrowing or lending, large gross assets (in excess of €500 million) and low or zero employment. While these firms pay corporation tax in Ireland (at reduced rates), there is considerable loss to other exchequers. The paper concludes that such tax haven type activities are unlikely to remain a viable part of future industrial policy in Ireland.