Three multinational companies – Apple, Microsoft, and Eli Lilly – accounted for almost half of Ireland’s corporate tax revenue in 2024, according to a report released Tuesday by the Irish Fiscal Advisory Council (Ifac).
The three firms collectively paid approximately €13 billion out of a total €28.1 billion collected in corporate tax, representing 46% of the State’s intake. Apple contributed roughly €5.8 billion, while Microsoft paid around €4.8 billion, and Eli Lilly accounted for approximately €2.2 billion, the Ifac report estimates.
The findings highlight what Ifac describes as the “exceptionally concentrated” nature of Ireland’s corporate tax base. The watchdog warned that such heavy reliance on a limited number of companies carries “significant risk.” Just two companies accounted for almost 40% of all receipts in 2024, the report stated.
The concentration of tax revenue from these three companies represents a significant shift. Between 2021 and 2024, Ireland’s corporation tax receipts nearly doubled, largely driven by increased payments from these top three taxpayers.
Apple’s substantial tax payment in 2024 includes approximately €14 billion resulting from its protracted legal battle with the European Commission. The Commission had ruled that Ireland had provided Apple with illegal state aid through a tax arrangement.
The shift in the top three corporate taxpayers also reflects changes in the pharmaceutical sector. Eli Lilly surpassed Pfizer, which previously held the third position, due to increased earnings from its weight-loss drugs, Zepbound, and Mounjaro. Pfizer’s earnings declined in 2024 as demand for its COVID-19 vaccine and related medicines waned.
Ireland’s corporate tax system operates with a headline rate of 12.5%, but effective tax rates for foreign multinationals are significantly lower, ranging from 2.2% to 4.5% on profits shifted to Ireland through a network of bilateral tax treaties. These lower rates are facilitated by various base erosion and profit shifting (BEPS) tools, including arrangements like the “Double Irish” and “Single Malt,” as well as capital allowances for intangible assets.
The reliance on multinational tax revenue is a key component of the Irish economy. In 2016-2017, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labor force, and generated 57% of Irish OECD non-farm value-add. As of 2017, U.S.-controlled businesses comprised 25 of the top 50 Irish firms, accounting for 70% of their revenue.
The Pillar Two rules, designed to ensure a global minimum corporate tax rate, were legislated in Ireland with effect from January 1, 2024, for the Income Inclusion Rule (IIR) and January 1, 2025, for the Undertaxed Profits Rule (UTPR).
