Where the math is defensible.
Long-form research on live enterprise decisions. Publication is selective. Every number traces to a named source. No takes without evidence.
Ireland at Fifteen Percent: The Pillar Two Transition and the Stickiness of the Cluster
The 12.5 percent rate that built modern Ireland is gone for the largest multinationals, replaced by a 15 percent floor enforced through QDMTT and IIR. Corporate tax receipts kept climbing through the transition. The question is whether agglomeration outlasts arbitrage.
Ireland transposed EU Council Directive 2022/2523 through Part 4A of the Taxes Consolidation Act 1997, inserted by the Finance (No. 2) Act 2023. From accounting periods beginning on or after 31 December 2023, Irish constituent entities of multinational groups with consolidated revenue at or above EUR 750 million pay an effective 15 percen...
Ireland's Corporation Tax Windfall and the Future Ireland Fund: Sovereign Savings Against a Concentrated Base
The 13.0 billion euro Apple State Aid disbursement and a 27.8 billion euro 2024 corporation tax take pushed Ireland's headline surplus to 25.0 billion euro, but the Irish Fiscal Advisory Council estimates that ten firms generate 56 percent of receipts. The Future Ireland Fund and the Infrastructure, Climate and Nature Fund are the policy answer for the 2025 to 2035 window, and Pillar Two and US tariff risk are the live threats.
Ireland's exchequer collected 27.8 billion euro in corporation tax in 2024, equal to 33 percent of total tax revenue, with an additional 14.1 billion euro in Apple back taxes plus interest received in tranches under the Court of Justice of the European Union ruling in C-465/20 of September 10, 2024. The 2024 general government surplus rea...
Trump pharma tariffs and the US drug supply chain through 2026: Section 232, Ireland exposure, and the API reshoring arithmetic
The April 2025 Section 232 pharmaceuticals investigation, the Ireland headline import number, and the India and China API base together define the 2026 corridor. We map the import stack, the announced reshoring capex, the IRA Year 2 negotiation list, and the 2026 to 2028 buyer playbook.
The Trump administration commenced a Section 232 pharmaceuticals investigation on April 1, 2025 under the Bureau of Industry and Security (BIS) at the Department of Commerce, with public threats of duties between 25 and 200 percent on imported finished drugs and active pharmaceutical ingredients (APIs). United States imports under Harmoni...