Professor Jim Stewart:

The general rule in Irish corporation tax law, and in US law, is that tax residency occurs where one is incorporated. In the case of Ireland, if a company is foreign owned then different rules apply. These rules relate to where one is management controlled or where there is a permanent establishment if the management and control applies. The US Bureau of Economic Analysis data uses this latter approach and its data relates to subsidiaries incorporated in Ireland. The US data is very useful because it looks at US data, by survey, across 53 different countries which means anomalies are removed. Companies are not allocated to two different countries so the data has an economical basis. The US Bureau of Economic Analysis will have spent a considerable period working out the anomalies, consistent through time, and comprehensive in looking at profits of US companies in particular countries.

I do not accept that because companies are incorporated in Ireland that they are reporting the profits of their Dutch and other subsidiaries because that would be double counting. They would say that the subsidiary in Australia, for example, would also be included in the Irish data.