Corporation tax has become – in a relatively short period of time – the Government’s third largest tax base, accounting for €1 in every €5 collected.
It generated €11.8 billion or 21 per cent of total tax receipts last year, nearly three times the total collected in 2014.
The additional revenue is linked to the onshoring of assets here by multinationals, particularly IP (intellectual property) assets and increased corporate profitability generally.
Although it has been a windfall for the exchequer, it comes with a health warning as 56 per cent of receipts from the business tax come from just 10 large firms, making it highly concentrated and potentially vulnerable to shocks.
Based on company filings, reports and other data, we’ve attempted to compile a list of the top 10 corporate tax payers in the Republic. The list is by no means definitive as several firms don’t publish tax payments here. The figures are also subject to a number of caveats, most notably what a company files as a tax charge is not necessarily what it pays in tax.
The companies involved have multiple subsidiaries – some loss-making – which makes quantifying their tax liabilities in a given year difficult. Some of the tax numbers are also derived from the consolidated accounts of parent companies and therefore overlap with tax paid in other countries.
1 Apple – €2.29bn
According to the financial accounts of its main Irish subsidiary – Apple Operations International Limited (AOI) – the iPhone maker paid a corporate tax charge of €2.286 billion in the Republic for the 12 months ending September 26th, 2020. The figure equated to 19 per cent of the Government's total corporate tax that year. The company, which is based primarily in Cork, employing around 6,000 people here, generated a turnover of €131 billion.
Apple was the first company to exceed $1 trillion (€884 billion) and $2 trillion in market value in 2018 and 2020 respectively. In 2020, it also successfully overturned a European Commission ruling that it owed Revenue €13.1 billion in back taxes. The commission is appealing that decision.
2 Microsoft – €1.84bn
According to its most recently filed accounts, Microsoft Ireland Operations Limited, the software giant's main Irish subsidiary, paid tax of $378.4 million on the back of $46.7 billion in revenue for the financial year ending June 20th, 2020. Separately another Microsoft subsidiary, known as Microsoft Research Ireland, paid corporation tax of $1.7 billion on the back of $33.4 billion in turnover.
Microsoft, whose products include Windows and Office, is the world’s biggest software company. It has had a manufacturing base here since 1985 and now employs more than 1,200 staff directly at its operations in south Dublin. About 700 contract staff also work there.
3 Google – €622m
Company documents show Google Ireland Limited agreed a €218 million tax settlement with Revenue in 2020 which formed part of a total corporate tax bill of €622 million. The internet giant’s Irish subsidiary reported turnover of €48.4 billion in 2020. A dividend was not paid for 2020, but according to the accounts, the company paid interim dividends of €3 billion to its parent.
Google Ireland is the Europe, Middle East and Africa (EMEA) headquarters for Google and provides technical, sales and operations support to customers in more than 50 countries and employes roughly 7,000 staff.
In 2020, the technology giant overhauled its global tax structure and consolidated all of its intellectual property holdings back to the US, effectively its use of the so-called "double Irish" tax loophole, which has been used by companies to channel international profits through Ireland and on to tax havens such as Bermuda – putting them outside the US tax net.
The US pharma giant and company behind one of the world's leading Covid-19 vaccines has multiple subsidiaries in the Republic. Most are controlled by CP Pharmaceuticals which is based in the Netherlands, which also controls Pfizer subsidiaries in other countries. According to the most recent accounts for CP Pharmaceuticals, it had a tax liability of $1.9 billion for the 12 months to November 30th, 2020. The accounts don't break out how much was paid to Revenue here, but it is likely to have been substantial.
Pfizer was one of the first pharmaceutical companies to locate in the Republic with a €10 million investment in 1969. Its blockbuster anti-cholesterol drug Lipitor was at one stage the biggest selling drug in the world while its little blue Viagra pills have revolutionised the sex lives of millions. It employs some 4,000 staff here.
5 MSD (Merck, Sharpe and Dohme)
MSD's Irish sites manufacture approximately half of the company's top 20 products and employ approximately 2,700 staff. One of its plants in Swords in Dublin, known as Swords Laboratories, reported a tax charge of $310.5 million (€274 million) for the year ending December 31st, 2019.
The company, which trades as Merck in the United States and Canada, reported global sales of $48 billion in 2020. The company's recent success has been built on the HPV vaccine Gardasil. It also sells the chickenpox vaccine, Varivax, which is among the top five vaccines globally by sales.
MSD is developing a new biologics plant in Swords, which is expected to open in 2021. It will focus on manufacturing Merck’s top-selling cancer drug, Keytruda.
6 Johnson &Johnson
Johnson & Johnson (J&J), the US pharma group behind the one-shot Covid-19 vaccine, has been operating in Ireland since 1935. The company produces a range of healthcare, personal care and over the counter products and is expecting annual sales of up to $94.6 billion in the current financial year, boosted by a forecasted revenue of over $2.5 billion from its Covid vaccine. Again it operates multiple facilities in Ireland, making its tax payments here difficult to track.
The consolidated accounts for J&J’s parent group, for the year ending December 31st, 2019, indicates it paid $2.7 billion (€2.4 billion) in international taxes outside the US, which include taxes paid here.
7 Facebook - €266 million
The social media giant's largest Irish subsidiary – Facebook Ireland Limited – paid a tax charge of €266.3 million on its activities in the Republic for the 12 months ending December 31st, 2020, according to accounts submitted to the Companies Registration Office.
The US company, which owns Facebook, Instagram, WhatsApp and Oculus, employs 6,000 people across multiple Irish locations, including its international headquarters in Dublin, its data centre in Meath and its "Reality Lab" office in Cork. It is also developing a new headquarters building in Dublin's Ballsbridge. The latest set of accounts indicate Facebook Ireland set aside more than €1 billion to meet potential fines the company could face from regulators.
The chipmaker's main Irish subsidiary – Intel Ireland Limited – is a branch plant of a company based in the Cayman Islands and therefore does not disclose the profits it generated or taxes it paid here. The US company generated almost $78 billion in sales in 2020 aided by a global shortage of chips.
While the business is likely to be highly profitable in Ireland, it also is likely to have large capital allowances linked to several multi-billion euro chip fabrication plants on its site in Leixlip, Co Kildare where it employs the bulk of its 5,000 staff here. The Leixlip facility is the company's largest outside the US.
The company says it has made no final decision regarding future investments as media reports suggest Ireland has lost out on a planned €80 billion spend by the group to increase its manufacturing capacity. Intel Research and Development Ireland Limited, the chip giant’s Irish research arm, said corporation tax for the year ending December 2020 came to $3 million.
The world's largest medical device company became the largest Irish-based company following its $50 billion reverse takeover of Dublin-domiciled surgical supplies group Covidien. The Minneapolis-based business moved its corporate headquarters to Ireland in a new holding company, Medtronic plc, as part of the inversion deal. It employs more than 2,000 staff here, mainly at its facility in Galway.
The company does not disclose the tax it pays in the State but a recent filing in the US indicated it paid – for the year ending April, 2020 – $878 million (€775 million) in taxes outside the US, a significant chunk of this is likely to have been paid to Revenue here.
10 Coca-Cola – €256 million
According to the latest accounts of Coca-Cola’s main Irish subsidiary, European Refreshments, the soft drink giant paid a tax charge of €255.9 million in the Republic in 2020. The accounts show that profits at the Irish arm of Coca-Cola rose from €1.7 billion to €2.1 billion last year despite turnover dropping 12 per cent to €4.3 billion, a decline put down to Covid disruption.
European Refreshments makes and sells Coca-Cola concentrate to bottlers worldwide. The accounts also show Coca-Cola’s subsidiary here paid out a dividend of €1.4 billion to its parent company, Atlantic Industries, which is based in the Cayman Islands.