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All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. Most are refreshed every 3-7 years based on

All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. Most are refreshed every 3-7 years based on OECD (or EU) recommended standards. Ireland's laws and treatment are 100% compliant. Rather than competing and reducing their tax rates countries like France prefer to moan, as politically they can’t be seen to favour big bad businesses. This of course was no problem with the EEC where Germany, France and the other ex-colonial powers made out like bandits selling their coal and steel to Ireland and the CT being paid there. Enter an English-language dominated SaaS economy from the 90s and they got caught out as they were more interested in domestic economic protectionism than dealing with the realities of a paradigm shift towards tech. We pivoted completely to an information economy and service based economy from a predominately agrarian one. Now have a look at the tech job market in 2024 in Dublin versus Paris, Frankfurt, Berlin, Barcelona etc.. If any one of our EU or the other non EU countries were really dissatisfied with Ireland, they have the right to withdraw at any time.

quonn 2y ago
Look, it's nice that Ireland is finally not a poor country anymore. That's primarily due to EU politics and support. It is, however, economically nowhere even close to France or Germany, no matter how large you think the "tech job" market there is [0]. > If any one of our EU or the other non EU countries were really dissatisfied with Ireland, they have the right to withdraw at any time. Who should withdraw from what? [0] For the facts regarding economic strength, read this document by the central bank of Ireland. https://www.centralbank.ie/docs/default-source/publications/economic-letters/vol-2021-no-1-is-ireland-really-the-most-prosperous-country-in-europe.pdf https://www.centralbank.ie/docs/default-source/publications/...
- piltdownman 2y ago
  How could we be? We're not a post-colonial power like France or Germany who spent years exploiting the African continent in egregious human rights violations. It is literally only since 2021 that we have reached our pre-English Genocide population levels of 1851 https://www.theguardian.com/world/2021/aug/31/ireland-population-surpasses-5m-for-first-time-since-1851 https://www.theguardian.com/world/2021/aug/31/ireland-popula... Germany has 20x our population, France is not far off it. Neither has anything close to the job market per capita in the IT and Services sector that Ireland has. As for us dragging ourselves up, that has more to with our special relationship with the US. The EU were initially helpful with infrastructural development, access to a Common Market, and to drag us out of the Vatican Law era, but we gave up a huge amount of fishing rights to do so - massively enriching spain, portugal and france who had overfished their own waters. Note also we're not part of Schengen, but maintain a CTA (Common Travel Area) with the UK. Eventually the EU took the legs out from under us in 2008 and forced us at gunpoint to bail out unsecured german bondholders to maintain the integrity of the Euro and prevent a contagion run on German Banks. Irelands FDI sector was highly developed in the late 80s and combined with entities like Enterprise Ireland - ranked first in the world of venture capital investors by deal count in 2020 - hammered home the advantage via our highly-educated English speaking workforce and relatively low cost of living. Even now the number of investments completed by Enterprise Ireland was 42% more than its nearest competitor, French sovereign wealth fund Bpifrance.
  - quonn 2y ago
    Germany was never a significant colonial power and did not extract much value from them. Especially not compared to Spain, Portugal, the United Kingdom, France, the Netherlands or Belgium. > Germany has 20x our population, France is not far off it. Neither has anything close to the job market per capita in the IT and Services sector that Ireland has. If you say so. And yet those employees are payed less. These jobs exist because Ireland gave US companies large tax breaks and because it is an English-speaking country. Otherwise they would perhaps been based in the UK before Brexit. It's good that Ireland attracts business, but encouraging tax dodging is not the way and this particular judgement is an opportunity to acknowledge this.
    - piltdownman 2y ago
      We encouraged or facilitated nothing of the sort. The commission has caved to political pressure and has fabricated a state aid case. The original general court ruling was unequivocal. This ruling has been overturned by the ECJ - absolutely shamefully; with the entirety of their case is that Apple, and Apple alone were the beneficiary of state aid. That is demonstrably untrue.
      - quonn 2y ago
        So according to you everyone is wrong, all the courts, all the other EU countries (which unjustly are wealthier than Ireland due to colonialism), the commission and the court and of course the decision taken by it.
- csomar 2y ago
  > It is, however, economically nowhere even close to France or Germany, no matter how large you think the "tech job" market there is [0]. Shouldn't they then keep their low-tax environment so that they can catch up to the rest of Europe ;)
realityking 2y ago
> All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. That is completely wrong on multiple levels. - You’re likely thinking of the double taxation treaties that follow the OECD model convention. These hardly get refreshed every 7 years. The German/Irish one is from 1962, the French/Irish one is from 1966, and the UK/Irish one from 1976. - The OECD’s BEPS multilateral tax treaty has now 85 state parties, including Ireland - There are other example of multilateral tax treaties, e.g. the Nordic countries have a multilateral double taxation treaty - There’s plenty of EU legislation around taxation covering predominantly VAT and excise duties bit also such details as the tax treatment of moving personal property between member countries or how royalty payments between associated companies are treated
- piltdownman 2y ago
  TBF VAT is its own special category which I'd omitted so I'll give you that. OECD BEPs isn't a tax treaty per se, its a Multilateral Convention to Implement Tax Treaty Related Measures. Re: the Nordic treaty, Norway and Iceland aren't in the EU. > The German/Irish one is from 1962 Correct. Here's the 1962 version https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-1962.pdf https://www.revenue.ie/en/tax-professionals/documents/double... and here are the last three UPDATED versions https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2021.pdf https://www.revenue.ie/en/tax-professionals/documents/double... https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2014.pdf https://www.revenue.ie/en/tax-professionals/documents/double... https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2010.pdf https://www.revenue.ie/en/tax-professionals/documents/double...

quonn 2y ago

Look, it's nice that Ireland is finally not a poor country anymore. That's primarily due to EU politics and support. It is, however, economically nowhere even close to France or Germany, no matter how large you think the "tech job" market there is [0]. > If any one of our EU or the other non EU countries were really dissatisfied with Ireland, they have the right to withdraw at any time. Who should withdraw from what? [0] For the facts regarding economic strength, read this document by the central bank of Ireland. https://www.centralbank.ie/docs/default-source/publications/economic-letters/vol-2021-no-1-is-ireland-really-the-most-prosperous-country-in-europe.pdf https://www.centralbank.ie/docs/default-source/publications/...

piltdownman 2y ago
How could we be? We're not a post-colonial power like France or Germany who spent years exploiting the African continent in egregious human rights violations. It is literally only since 2021 that we have reached our pre-English Genocide population levels of 1851 https://www.theguardian.com/world/2021/aug/31/ireland-population-surpasses-5m-for-first-time-since-1851 https://www.theguardian.com/world/2021/aug/31/ireland-popula... Germany has 20x our population, France is not far off it. Neither has anything close to the job market per capita in the IT and Services sector that Ireland has. As for us dragging ourselves up, that has more to with our special relationship with the US. The EU were initially helpful with infrastructural development, access to a Common Market, and to drag us out of the Vatican Law era, but we gave up a huge amount of fishing rights to do so - massively enriching spain, portugal and france who had overfished their own waters. Note also we're not part of Schengen, but maintain a CTA (Common Travel Area) with the UK. Eventually the EU took the legs out from under us in 2008 and forced us at gunpoint to bail out unsecured german bondholders to maintain the integrity of the Euro and prevent a contagion run on German Banks. Irelands FDI sector was highly developed in the late 80s and combined with entities like Enterprise Ireland - ranked first in the world of venture capital investors by deal count in 2020 - hammered home the advantage via our highly-educated English speaking workforce and relatively low cost of living. Even now the number of investments completed by Enterprise Ireland was 42% more than its nearest competitor, French sovereign wealth fund Bpifrance.
- quonn 2y ago
  Germany was never a significant colonial power and did not extract much value from them. Especially not compared to Spain, Portugal, the United Kingdom, France, the Netherlands or Belgium. > Germany has 20x our population, France is not far off it. Neither has anything close to the job market per capita in the IT and Services sector that Ireland has. If you say so. And yet those employees are payed less. These jobs exist because Ireland gave US companies large tax breaks and because it is an English-speaking country. Otherwise they would perhaps been based in the UK before Brexit. It's good that Ireland attracts business, but encouraging tax dodging is not the way and this particular judgement is an opportunity to acknowledge this.
  - piltdownman 2y ago
    We encouraged or facilitated nothing of the sort. The commission has caved to political pressure and has fabricated a state aid case. The original general court ruling was unequivocal. This ruling has been overturned by the ECJ - absolutely shamefully; with the entirety of their case is that Apple, and Apple alone were the beneficiary of state aid. That is demonstrably untrue.
    - quonn 2y ago
      So according to you everyone is wrong, all the courts, all the other EU countries (which unjustly are wealthier than Ireland due to colonialism), the commission and the court and of course the decision taken by it.
csomar 2y ago
> It is, however, economically nowhere even close to France or Germany, no matter how large you think the "tech job" market there is [0]. Shouldn't they then keep their low-tax environment so that they can catch up to the rest of Europe ;)

realityking 2y ago

> All tax treaties and agreements between countries (including intra-EU) are bilateral country to country agreements. That is completely wrong on multiple levels. - You’re likely thinking of the double taxation treaties that follow the OECD model convention. These hardly get refreshed every 7 years. The German/Irish one is from 1962, the French/Irish one is from 1966, and the UK/Irish one from 1976. - The OECD’s BEPS multilateral tax treaty has now 85 state parties, including Ireland - There are other example of multilateral tax treaties, e.g. the Nordic countries have a multilateral double taxation treaty - There’s plenty of EU legislation around taxation covering predominantly VAT and excise duties bit also such details as the tax treatment of moving personal property between member countries or how royalty payments between associated companies are treated

piltdownman 2y ago
TBF VAT is its own special category which I'd omitted so I'll give you that. OECD BEPs isn't a tax treaty per se, its a Multilateral Convention to Implement Tax Treaty Related Measures. Re: the Nordic treaty, Norway and Iceland aren't in the EU. > The German/Irish one is from 1962 Correct. Here's the 1962 version https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-1962.pdf https://www.revenue.ie/en/tax-professionals/documents/double... and here are the last three UPDATED versions https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2021.pdf https://www.revenue.ie/en/tax-professionals/documents/double... https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2014.pdf https://www.revenue.ie/en/tax-professionals/documents/double... https://www.revenue.ie/en/tax-professionals/documents/double-taxation-treaties/g/germany-protocol-2010.pdf https://www.revenue.ie/en/tax-professionals/documents/double...