The Commission has not sought information on the so-called 'Double Irish' structure as part of its current review of corporate tax ruling procedures in various EU Member States. The Commission review is looking at practice in relation to the provision of advance tax rulings or opinions. The 'Double Irish' two-tier structure is an international tax-planning arrangement which has been designed and developed by tax and legal advisers. It relies on arbitrage between the different tax rules used in different countries to achieve a low level of taxation on foreign profits of companies not resident here and is not part of the Irish tax offering.
Differences arise in the legal and tax systems between countries. International tax planning takes account of these differences in national systems and rules. The only way to effectively deal with such arrangements is for countries to work together to examine these structures and to consider how international rules can be amended to ensure fair levels of taxation. Ireland remains fully committed to this approach to ensure coherence in international taxation. In this regard, Ireland is participating in projects at EU and OECD level which aim to address international tax issues.