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Unpacking Discrepancies in American and Irish Royalty Reporting
In 2021, a striking discrepancy emerged in Ireland’s royalty payments to the United States. As shown in the first figure, Ireland reported paying approximately $106 billion to the U.S. for intellectual property use, yet the U.S. reported receiving only $24 billion from Ireland for these services. This stark difference, visible in reported trade data from the Organization for Economic Cooperation and Development (OECD),1In this post, we used “OECD-WTO: Balanced International Trade in Services？EBOPS 2010,” a database from the OECD that we accessed on July 15, 2024. is both recent and unique to U.S.-Ireland intellectual property transactions.
The discrepancy in royalty payments is truly distinct. First, the large discrepancy is specific to intellectual property royalties and does not extend to other service sectors. The second figure illustrates that for services excluding intellectual property royalties (non-IP services), the reporting discrepancy between the U.S. and Ireland was modest. In 2021, Ireland reported paying $63 billion to the U.S. for non-IP services, while the U.S. reported receiving $51 billion―a much smaller gap compared to the IP royalty discrepancy.
Second, historical data show that this discrepancy emerged suddenly in 2020, as the U.S.-Ireland trade relationship had previously been stable. Third, the anomaly is also unique to the U.S.-Ireland relationship, as neither country exhibits such a large reporting disparity with any other developed economy.
This unique and substantial discrepancy in royalty reporting between the U.S. and Ireland presents a complex puzzle in international taxation. To unravel this issue, our analysis proceeds in two key stages
The discrepancy in royalty payments is truly distinct. First, the large discrepancy is specific to intellectual property royalties and does not extend to other service sectors. The second figure illustrates that for services excluding intellectual property royalties (non-IP services), the reporting discrepancy between the U.S. and Ireland was modest. In 2021, Ireland reported paying $63 billion to the U.S. for non-IP services, while the U.S. reported receiving $51 billion―a much smaller gap compared to the IP royalty discrepancy.
Second, historical data show that this discrepancy emerged suddenly in 2020, as the U.S.-Ireland trade relationship had previously been stable. Third, the anomaly is also unique to the U.S.-Ireland relationship, as neither country exhibits such a large reporting disparity with any other developed economy.
This unique and substantial discrepancy in royalty reporting between the U.S. and Ireland presents a complex puzzle in international taxation. To unravel this issue, our analysis proceeds in two key stages
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