Interesting article at Forbes on Apple’s tax position in Ireland: pity the author doesn’t really appear to have thought things through all the way or developed the discussion usefully:
The Irish Revenue issued a Tax Statement of Practice at the end of July (SP-CT/01/10), removing withholding taxes from patent royalties paid to associated companies in another EU member state.
At the moment Ireland gives tax relief for know-how and scientific research. However, the new rules widen the scope of intangible assets to include brands and trademarks. Companies carrying out a trade will be able to claim a deduction for the capital costs of acquiring specified intangible assets. The tax deduction is available for offset against income from exploiting IP assets or from the sale of goods/services that derived most of their value from IP.
From A&L Goodbody, news that the Irish Finance Bill, published on 7 May, provides for tax depreciation for expenditure incurred after 7 May 2009 on the acquisition of qualifying IP and extends the stamp duty exemption to ensure that transfers of IP qualifying for tax depreciation also qualify for exemption from stamp duty.
The relief is available up to a maximum of 80% of the taxable income against which the deduction may be taken (excess depreciation may be carried forward). As Ireland’s corporation tax rate for trading income is 12.5%, the new measures potentially allow for a 2.5% effective rate to be achieved (20% at 12.5%).
From IP Finance: Ireland’s tax proposals for IP investment and transactions