Double Irish
The Double Irish was a tax structure, now closed, used mainly by US technology companies. It exploited a mismatch between Irish and US rules on tax residency to create a company that was resident nowhere for tax purposes. One Irish-registered company was controlled from a tax haven, so it counted as resident in the haven under US rules and not resident in Ireland under Irish rules; a second Irish company held the valuable intellectual property and charged royalties. Profit flowed between the two with almost no tax applying anywhere. Ireland closed the Double Irish to new entrants in 2015, and existing arrangements were wound down by the end of 2020.
ByLoopholeKiln EditorialPublished
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Example: a tech giant paired the Double Irish with a Dutch conduit (the "Double Irish with a Dutch Sandwich") to hold tens of billions in non-US profit at close to a zero rate.
Why it matters to a small business: this structure needed hundreds of millions in existing intellectual property, a global corporate group and dedicated legal and tax teams. It was never available to any business that was not already a giant.