> The tax strategies these companies use are known

Links to an article from 2017 about a tax loophole that was closed in 2020 [0]. As an Economist that by his Wikipedia article [1] dedicates so much of his time talking about the Irish tax regime, he should be well aware of this fact.

[0] https://budgetmodel.wharton.upenn.edu/issues/2024/10/14/the-... [1] https://en.wikipedia.org/wiki/Brad_W._Setser

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muststopmyths 5 days ago | parent | next [-]

You are talking about the "Double Irish", which was scotched (sorry) in 2020 by Ireland.

The link under your quoted line in the TFA seems to be talking about Apple (and others) preparing for the end of the Double Irish by finding other tax havens.

"Elite tax advisers help Apple Inc. and other corporate giants skirt impacts of crackdown on 'Double Irish' maneuvers."

So, I don't see what's invalid about the TFA's point, which is about tax avoidance in general

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cowsandmilk 5 days ago | parent | prev | next [-]

The article is specifically about how Apple doesn’t use the double Irish loophole any more as they moved to Jersey…

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refurb 5 days ago | parent | prev | next [-]

Yup, this article isn't great.

As someone close to pharmaceutical manufacturing, the reason why the manufacturing is done in Ireland is for tax benefits for sales in Europe.

So why not have a US factory for US sales? Because it's much more expensive and complex to have two separate factories making the same drug. It's far easier to just scale the Irish factory to serve all global sales.

Even the same companies with Irish factories have US factories as well. It's not like any tax benefit moved that out of the US as well.

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kgwgk 5 days ago | parent [-]

Most of the value is in the patents, not in the manufacturing. Did they also expatriate that “accidentally”?

If Pfizer operates in the US at a loss (or at least they did in 2018-2020) and all the profits are booked elsewhere it was their choice.

https://www.finance.senate.gov/imo/media/doc/wyden_pfizer_in...

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refurb 5 days ago | parent [-]

No, that’s entirely intentional.

The IP and manufacturing are linked because you can’t manufacture something from commercial sale if you don’t have patent rights.

But the licensing of patent rights was done for tax advantage in the EU, not the US (generally).

Taxes are important but not the sole determinant of where they manufacture.

	▲	kgwgk 5 days ago \| parent [-]
		The manufacturing is in one place. The IP in another place. Both places chosen mostly for tax reasons in this case. Paying zero taxes in the US is a lucky side-effect.

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readthenotes1 5 days ago | parent | prev [-]

It is also kind of an odd article because his assertion "After the 2017 Tax Cuts and Jobs Act (TCJA), imports from Ireland soared." is not at all borne out by graph that immediately follows.

Switzerland is a whole different matter, but such carelessness doesn't improve trust

	▲	dmurray 5 days ago \| parent [-]
		Right, the graph shows a continuous increase since 2017, which tracks the growth of the worldwide pharmaceutical industry in general ($800b in 2016 [0] to $1.4t in 2024 [1].) So actually, the proportion of pharmaceutical imports that were from Ireland remained constant until a spike in late 2024. And then there's this: > The top seven pharmaceutical companies are paying $10 billion or so in tax on their $70 billion in offshore profit. They are just paying all that tax abroad. So these companies already pay 14% in corporate tax. In the US, they'd pay 21% headline rate, but with room for deductions (I can't find a good source for what they actually pay, but here's [2] a bad source putting the R&D deduction alone at $15b/year across the top 8 companies). This 21% changed from 35% in the 2017 act the article criticises, though some deductions were also reduced. So corporate tax can't be the main differentiator here. It's nice, for balance, to see an article that says the problem with Trump is that he just isn't protectionist enough. But the arguments here don't hold up. [0] https://www.efpia.eu/media/219735/efpia-pharmafigures2017_st... [1] https://efpia.eu/media/2rxdkn43/the-pharmaceutical-industry-... [2] https://americansfortaxfairness.org/drug-firms-fight-restore...