Abstract

The use of tax havens is a pervasive part of modern economic activity. Treasury management subsidiaries who are key conduits in the global intra-firm movement of funds are often located in tax havens or in countries with tax haven type features. This paper shows how two recent European Court of Justice cases dealing with treasury management firms located in Ireland, have helped secure the legal and tax benefits of such operations. The paper examines financial flows and other financial characteristics of 46 treasury management firms based in Ireland for the period 1998–05. While financial flows are large, they are highly variable from period to period. These firms are highly profitable, but median employment is zero. The paper concludes that while recent court cases have supported the existence of both low tax regimes and treasury management type operations within the EU, their continued existence is opposed by many EU and non EU countries as being at variance with legislation to counteract tax avoidance.

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