Question on measuring foreign risk capital inflows during the Irish financial sector recovery

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October 25th, 2014

One of the key drivers behind the better-than-expected recovery of the Irish financial sector has been the strong inflow of foreign risk capital, particularly from U.S. “vulture funds” as they are inaptly named. This healthy demand for Irish banking assets has allowed the PCAR and PLAR plans for the domestic banks, and the unwinding of NAMA, to progress successfully. Similarly healthy demand for the Irish assets of foreign banks, such as Irish loan portfolios sold by Ulster Bank, has also contributed indirectly to the Irish financial sector’s partial recovery.
There is a risk capital inflow when a foreign institution buys a troubled loan portfolio or property portfolio from an Irish bank, or from an Irish subsidiary of a foreign bank, or from Nama. These risk capital inflows are not intermediated through the Irish banks and do not appear on their balance sheets. Prof. Brian O’Kelly (DCU) and I were able to trace the 2000-2009 destabilizing inflow and sudden outflow of foreign credit into the Irish banking sector using the aggregate Irish banking sector balance sheet Table A4.1 published by the Irish Central Bank. Question: how can one measure this new source of risk capital inflows? It seems healthy and stabilizing rather than (like in 2000-2009) unhealthy and destabilizing, but it still deserves to be measured accurately. Is it necessary to list all the individual deals and add them up? Has some hardworking analyst done that already? Is it possible to create a quarterly or annual time series? Answers on a postcard (or better on a spreadsheet) are welcome!

60th Economic Policy Panel

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October 25th, 2014

The Economic Policy Panel took place over the last couple of days  – the draft papers are here.  Topics included the impact of fiscal austerity; the role of migration in adjustment; and estimates of the impact of the TTIP.

The Guarantee

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October 24th, 2014

The Irish Times preview the film with the screenplay writer Colin Murphy and producer John Kelleher here.  There is also a short clip from the movie to whet the appetite. 

Having seen the Fishamble stage production of  Guaranteed! last year I am looking forward to the film version which goes on limited release next week.  They probably took some artistic license with the adaption but hopefully not too much.

Budget 2015 and the 2014 Finance Bill

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October 24th, 2014

The 2014 Finance Bill was published yesterday and it is available here with related documents.

There’s not a lot new in the Bill.  One of the very minor changes relates to mortgage interest relief, with the relief now available to Income Tax payers in Ireland (who derive the bulk of their income in Ireland) for qualifying loans on PPRs in the entire European Economic Area rather than just Ireland.  There are plenty of other minor changes.

On the changes to corporate residency rules announced in the budget The National Law Review in the US has published a useful article under the heading: Death of the “Double Irish Dutch Sandwich”? Not so Fast. re: Irish Incorporated Non-resident Companies.  It is available here.

Earlier in the week the Minister for Finance and the Opposition Finance spokespeople gave statements to the Dáil on the pre-budget statement of the Fiscal Advisory Council.  The transcripts of these Dáil statements are here.

“Have We Learnt Anything from the Crisis?”

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October 21st, 2014

The Bank of Latvia organised a conference on this topic last Friday: materials here.

The speeches by Coeure and Weidmann on the euro area are quite interesting;  I can recommend the presentations on Greece;  there were presentations on Ireland by myself and Craig Beaumont.

 

 

Austerity Talk at Battle of Ideas in London

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October 20th, 2014

The ‘Battle of Ideas’ festival held at the Barbican in London last weekend included a panel session entitled ‘Piigs can’t fly: Democracy/Technocracy/Austerity’. I was invited to make a 7-minute presentation of my views as expressed at various crisis conferences over the years:

Back in 1986, long before most people imagined that the single currency would really come into being, Paul Krugman wrote of the potential fiscal co-ordination problem: a bias towards excessive restriction because each country ignores the impact of its actions on the exports of others. “Achieving co-ordination of fiscal policies is probably even harder politically than co-ordination of monetary policies. There is not even temporarily a natural central player whose actions can solve the co-ordination problem. None the less, in surveying the problems of European integration, it is hard to avoid the conclusion that this is the systemic change most needed in the near future”.

Without this problem ever having been addressed, the potential for exchange-rate realignment was locked down. As many US economists warned, the euro was a federalist project lacking in federalist foundations, whether minimalist (banking union or federalist insurance schemes) or maximalist (a Washington-style federal budget).

In the face of this existing (anti-Keynesian?; pre-Keynesian?; antediluvian?) institutional structure, Ireland had no choice but to impose austerity (which would have been required even in the absence of the disastrous bank guarantee of 2008). The large primary budget deficits – which meant that government spending would still far exceed tax revenues even if interest payments ceased – precluded debt default.

The actions of the ECB in 2010 in forcing us to pay off remaining unsecured bank bonds (by threatening to cut off liquidity) appear to have been beyond its mandate and it is difficult to think of any reason not to support economist Colm McCarthy’s call for this to be brought to the ECJ. But, as he notes, the need for  retrenchment would have remained.

The Irish experience under austerity has been distinguished by remarkable industrial peace. Paddy Teahon, the chief civil servant behind social partnership, argued that the process had promoted a shared understanding among unions, employers and the government of the key mechanisms and relationships that drive the economy. I wrote back in 2009 that “the Teahon view will be seen to be of validity if some agreement can be reached to reduce public-sector pay until the current crisis is overcome”.

As to whether austerity has worked, it has achieved what it was supposed to achieve, which was to close the deficit and slow the accelerating debt ratio. It was never supposed on its own to get the economy back to work, but rather to position the economy well for when markets rebounded. The flexibility of the labour market makes it easier for Ireland to bounce back from austerity than is the case for Greece for example. So does the openness of the economy, as long as export markets recover.

[All of the other panellists having been hostile to ‘the displacement of democracy by technocracy’, I suggested that:] Many or most economists of my acquaintance in Ireland were content enough with the policies espoused by, and implemented at the behest of, the troika. Technocracy can be viewed as an advantageous buffer between government and – on the other hand – purveyors of snake oil and the representatives of powerful entrenched interests (though technocrats too are not immune, of course, from regulatory capture).

Budget 2015

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October 15th, 2014

There’s plenty to discuss from yesterday’s announcements but any OP is not likely to be followed by related comments.

All the relevant documents from the Department of Finance are here.

This is a summary of the aggregate budgetary changes (in €million).

Here are two vintages of the debt interest table.  First from the April 2013 SPU.

And this from yesterday’s Economic and Fiscal Outlook:

There are lots of opinions I’m sure on how this (temporary?)  improvement was used.

The Great Mortgaging

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October 14th, 2014

Òscar Jordà, Moritz Schularick, and Alan Taylor provide a little historical perspective on banks’ mortgage lending here.

Economics and Psychology Workshop

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October 12th, 2014

The seventh annual one day conference on Economics and Psychology, co-organised by researchers from UCD, ESRI and NUIM, will be held on October 31st in the UCD Geary Institute. The purpose of these sessions is to develop the link between Economics, Psychology and cognate disciplines in Ireland. A special theme of these events is the implications of behavioural economics for public policy though the workshops have covered work across all areas of intersection of Economics and Psychology. Programmes from the previous six events are here. We welcome students, academics, policy-makers, industry representatives and others with an interest in this area. Registration is free of charge but you should sign up on the link below if you are attending. Other questions about the event can be addressed to Liam.Delaney@stir.ac.uk

Sign up to attend here 

The programme is available below.

Read the rest of this entry »

Sinking, fast and slow

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October 11th, 2014

For well over a year now some of us have been pointing out that the Eurozone crisis was entering a very dangerous phase, in which slowly increasing unemployment would eat away at the foundations of Europe’s societies, while short-sighted politicians and excitable journalists proclaimed that the Euro was saved. The invaluable Eurointelligence has been doing a great job recently tracking the apparently inexorable deterioration in the economic fundamentals of the Eurozone, with Germany itself now apparently affected. But for both political and personal reasons I find myself worrying most about France.

Twiddling their thumbs and hoping that something (the economy) will turn up, flawed macroeconomic policy notwithstanding, seems to have been the French government’s master plan up till now. As a result it is hard to see Francois “Say” Hollande, or any other Socialist for that matter, getting through to the second round in 2017.

You may think that Paul Krugman is being too alarmist when he raises the possibility of President Le Pen, and I hope you are right. But Sarokozy’s apparent return to the political fray does worry me. Of course, you may think that if he wins the UMP nomination, the Left will rally round and vote for him when it comes to the second round.

How confident are you about that?

Mental Health and the Irish Economy

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October 11th, 2014

A long literature has examined the role of  economic factors in promoting well-being. This has been a particularly active area for the last decade or so in Economics (summary of recent workshop we did on this topic with readings etc.,). Lately, a major topic of interest has been the role that mental health plays in producing economic outcomes at individual level. For example, an influential 2011 PNAS paper pointed to dramatic long-run economic effects of early life mental health conditions (see my review paper with one of the authors).  Richard Layard has called mental health the new frontier of labour economics and argued for mass expansion of mental health research and treatments. A big focus of the discussion has been the idea that mental health has been systematically discounted compared to physical health conditions in terms of health funding. Various proposals have been put forward to enhance the profile of mental health service in the UK (the recent speech by Nick Clegg one of most prominent).

A few major points to come from this literature and worthy of wide debate in the Irish context include:

The utility losses (for want of a better phrase) of mental health conditions are enormous even outside of effects on productivity and income (e.g. paper here). The interaction of this with physical conditions is also very important. Chronic pain is one particularly important area that should have greater priority in debates on health care (see Alan Krueger on this here).

Childhood mental health has dramatic effects on later life economic outcomes. There is a strong rationale to increase funding for child mental health research and services.  Many childhood mental health problems are practically ignored for the purpose of policy-making. For example, there exists almost no evidence on the long-run effects of prescribing stimulants to children diagnosed with ADHD with recent papers not exactly painting a glowing account of their usefulness (e.g. paper by Janet Currie here).  If you reflect on it, it really is an odd state of affairs that such important questions are neglected. The role of school mental health services for primary school children and teenagers is another area that is important to debate more given the hugely predictive effect of early mental health on life-long trajectories.

Lord Layard and others have argued for a substantial expansion of talk-therapies and a wider roll-out across society (short article outlining this view here; see also Layard and Clark’s recently released book Thrive). In the context of high rates of unemployment still in Ireland and in particular high rates of youth unemployment, this is worth discussing a lot more in the Irish context. Developing funding streams for large-scale referrals for brief talk-therapies is one of the most concrete suggestions to come from the recent literature.

There is a strong rationale for examining the proportion of health funding allocated to mental health in Ireland. It is widely documented  that mental health services in Ireland are given less priority compared to other countries (e.g. recent report here also O’Shea and Kennelly report).

Job Opportunity – Senior Researcher

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October 10th, 2014

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Hair of the Dog?

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October 9th, 2014

Michael O’Sullivan’s latest Dublin Review of Books piece is here, and it is well worth reading.

10-year bonds issued at 1.63%

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October 9th, 2014

NTMA note here.

Europe and the World

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October 8th, 2014

IMF WEO here

 

Martin Wolf on the Geneva Report here

Mario Monti on public investment in Europe here

Ireland

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October 8th, 2014

Summary of ESRI QEB here.

Cronin-McQuinn paper on macro impact of fiscal policy here.

Central Bank macro-prudential regulations here.

Jim Stewart’s FT article on taxation of corporates here.

TASC Budget 2015 Briefing

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October 8th, 2014

Available here.

Hugh Rockoff on what the US learned from WW1

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October 8th, 2014

The latest on the VoxEu series on the economics of World War 1 is available here.

IMF 2014 Triennial Surveillance Review

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October 7th, 2014

Documents here.

Central Banking Boundaries

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October 7th, 2014

The UCD Economics Society speech by Patrick Honohan is here.

Dublin Economics Workshop 2014

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October 6th, 2014

This year the DEW, kindly sponsored by the Dublin Chamber of Commerce, will be held at the River Lee Hotel in Cork City on Friday and Saturday, the 17th and 18th of October. This year’s programme is here.

All bookings and reservations for the event can be made from here.

This is the 37th DEW annual conference and will begin with a number of parallel sessions on Friday afternoon.  Over the two days there will presentations across a range of topics from 35 people including policymakers, academics, commentators and members of the business community. 

On Friday evening Jerry Dwyer of Clemson University will give a plenary session on ‘quantitative easing’ while the final session on Saturday will be a panel discussion on ‘fiscal policy for the long haul’ and will include a contribution from Robert Watt, Secretary-General of the Department of Public Expenditure and Reform. 

Shifting tax burden and investment is way forward

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October 4th, 2014

My thoughts on budgetary policy in the run up to Budget 2015 are here in today’s Irish Times.

The Irish Case for LTV and LTI Caps on New Mortgage Lending

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October 3rd, 2014

The Irish Central Bank discussion paper on macro-prudential policy tools published yesterday seems to be a trial balloon for possible caps on Loan-to-Income (LTI) and Loan-to-Value (LTV) ratios for new residential property mortgages in Ireland. The general theory behind imposing these limits is laid out clearly in that document; there is no reason to repeat it here. I want to discuss some notable features of the Irish environment which strengthen the case for these caps (but do not make the decision easy).

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Recruitment: Graduate Economists in the Irish Government Economic & Evaluation Service

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October 1st, 2014

Details here.

Presentation of Geneva Report: Thursday, October 2 at Noon

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October 1st, 2014

I will present the report in a Policy Institute seminar in TCD during 12-1 tomorrow Thursday in the IIIS seminar room (top floor, Arts Block). All welcome – no registration required.

A Macro-Prudential Policy Framework for Ireland

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October 1st, 2014

The Central Bank has published its framework here.

See also the new Economic Letters:

Macro-prudential tools and credit risk of property lending at Irish banks’ (Economic Letter Vol. 2014 no. 10) by Niamh Hallissey, Robert Kelly and Terry O’Malley

and

Housing market developments and household consumption,” by Daragh Clancy, Mary Cussen and Reamonn Lydon

Is there a fishing expedition going on?

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September 30th, 2014

Having read the Commission letter through it is clear that the game has moved to a different pitch.  The key issue is not the 1991 transfer pricing arrangement or its subsequently revision in 2007.  Yes, there was little objective basis for the 65/20 margins used and there was no reference to the arm’s length principle and the arrangement seemed to be reverse engineered, but there is nothing in the EC letter to say that the margins used were wrong and led to taxable income figures that were significantly out of line if a more careful and objective approach was taken in line with OECD standards (which weren’t introduced here until 2010). 

There is no doubt the 1991 advance pricing arrangement (APA) was put together in a pretty arbitrary manner as indicated by the minutes and notes taken by the Revenue official but that was as much the nature of the regime at the time rather than any special or preferential treatment to Apple.  The detailed nature of the records kept suggest it was not unusual.

Can it be argued that similar arrangements were not put in place for other companies?  APAs on a cost-plus basis for entities that engage in the activities attributed to the Apple’s Irish operations are not unusual. 

Apple Operations Europe:
- the "manufacture of a specialised line of personal computers."
-  providing "shared services to Apple companies in Europe, the Middle East and Africa (EMEA) region, including payroll services, centralised purchasing and a customer call centre."

Apple Sales International:
- the "procurement of Apple finished goods from third-party manufacturers"
- the "onward sale of those products to Apple-affiliated companies and other customers"
- "logistics operations involved in supplying Apple products from the third party manufacturers to Apple-affiliated companies and other customers."

Manufacturing, shared services, procurement and logistics are not high-profit activities.  The Commission can argue that the 65/20 cost-plus margins in the 1991 APA and the updated margins in the revised 2007 agreement were "wrong" but they are unlikely to result in a material difference to the amount of tax Apple would have had to pay in Ireland.  In monetary terms, any finding here would be relatively insignificant.

It is pretty clear that the issue has moved on and that these transfer pricing arrangements are no longer central.  The key issue is Apple’s intellectual property, or more precisely, the location of Apple’s intellectual property.

If we look at the five items requested by the Commission in June letter published this week none of them relates to the pricing agreements.  The information requested was:

- Provide the financial accounts of ASI and AOE for the period 2004-2013, in particular the P&L accounts.
- In the case of ASI single out in the P&L the amount of passive income each year and specifying if such passive income comes from Ireland.
- Provide the number of full time equivalent employees (hereinafter “FTE”) of ASI and of AOE over the same period (each end of reporting period).  Provide the FTE of the Irish branch of ASI and of AOE for the same period (each end of accounting period).
- Provide the cost sharing agreement between Apple Inc., ASI and AOE in all its variations since 1989 until the last modification.
- Describe in detail the type of intellectual property covered by the cost sharing agreement.

It is clear the Commission are focusing on the ASI subsidiary as a whole and not just its Irish branch.  The key issue is whether any of the intellectual property rights held by ASI are located in Ireland.   Last year’s US Senate report contained a good deal of information on ASI. The post continues below the fold with a a selection of quotes relating to ASI, and its parent AOE, in the Senate report.

Read the rest of this entry »

EC letter to Ireland on Apple State-Aid Case

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September 30th, 2014

The document is here.

There is a lot in it and the extracts here just focus on one element of it: a 1991 transfer pricing agreement that was done on a cost-plus basis, i.e. the profit attributed to the Irish operation was based on the costs incurred by the Irish operation.  This is not an unusual transfer pricing basis and, as expected, the amounts involved are relatively small, i.e. not billions.

The quirk is the structure of the agreement. For example the 1991 agreement for Apple Operations Europe was  [from paragraph 31]:

According to that ruling, the net profit attributable to the AOE branch would be calculated as 65% of operating expenses up to an annual amount of USD [60-70] million and 20% of operating expenses in excess of USD [60-70] million.

In the notes of a meeting (attendees not provided) it was said that (paragraph 37):

Following further discussions it was agreed that, subject to receiving a satisfactory outcome to the capital allowance question, to accept a mark-up of 65% of the costs attributable to the Irish branch. In addition it was agreed to accept a mark-up of 20% on costs in excess of $[60-70]m in order not to prohibit the expansion of the Irish operations.

On the two margins applied the Commission notes the following (paragraph 63):

Second, the margin on branch costs agreed in the 1991 ruling, as described at recital (31), is either 65% or 20% depending on whether the operating costs are below or above USD [60-70] million. According to the excerpt at recital (37), the reduction of the margin after a certain level above USD [60-70] million would have been motivated by employment considerations, which is not a reasoning based on the arm’s length principle. In particular, the two margins of 20% and 65% are relatively far apart and, should the margin of 65% effectively constitute an arm’s length pricing, the margin of 20% would be unlikely to fall within the same range of pricing, while applying the same degree of prudence.

There are other elements as well including transfer pricing for some intellectual property that can be explored in the document.

Barking up the wrong Apple tree

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September 29th, 2014

There is lots of excitement this morning about a story in the Financial Times about the European Commission state-aid investigation into Apple’s tax arrangements in Ireland. The story first appeared online under the headline “Apple hit by Brussels finding over illegal Irish tax deals”. When put on the front page of today’s print edition the headline was “Apple hit by Brussels findings over Irish backroom tax deals”. The story begins:

Apple will be accused of prospering from illegal tax deals with the Irish government for more than two decades when Brussels this week unveils details of a probe that could leave the iPhone maker with a record fine of as much as several billions of euros.

Preliminary findings from the European Commission’s investigation into Apple’s tax affairs in Ireland, where it has had a rate of less than 2 per cent, claim the Silicon Valley company benefited from illicit state aid after striking backroom deals with Ireland’s authorities, according to people involved in the case.

The headline and story resulted in widespread opprobrium from the usual sources being directed at Ireland. The reality is that the headline is nonsense and the presentation of the story in the text was misleading (at best). Anyone with even a summary understanding of the issue would immediately see that, but there are plenty who love jumping to and jumping on adverse conclusions about Ireland’s corporation tax regime.

The errors include:

  • there are no “fines” in state-aid cases
  • the case does not involve “billions of euros”
  • there are no “preliminary findings”
  • there is no “rate of less than 2 per cent”

And that’s just the first two paragraphs!

At present Apple pays very little corporate income tax on its profit earned on sales made outside the US. These profits will be taxed based on the source-location of the risks, assets and functions from which the profits are derived. The risks, assets and functions that generate Apple’s profits are mainly in the US and under current rules the US is granted the taxing right for the bulk of Apple’s profits. The fact that the US allows Apple to defer the payment of this tax until the profits are transferred to a US-incorporated company is a matter for the US.

Sometimes we tend to use the word “repatriate” when it comes to these profits. But Apple’s non-US profits don’t have to be repatriated to the US; they go there directly and there is no stop-off in Ireland. Yes, Apple’s non-US profits are accumulated in Irish-incorporated companies but almost everything about these companies happens in the US.  Using US rules, Apple was able to create this situation and maintain that these companies did not have a taxable presence in the US.  The EC investigation will examine none of the headline issues about these companies highlighted in the US Senate Report last May.

The EC can only investigate the taxing of activity that happens in Ireland and decisions that are made in Ireland. In its June announcement, the EC said the Irish element of its investigation relates to:

the individual rulings issued by the Irish tax authorities on the calculation of the taxable profit allocated to the Irish branches of Apple Sales International and of Apple Operations Europe;

It is the profit attributed to just the Irish branches of the companies that is in question not the entire profits of these companies. In his opening statement to the US Senate hearing last May, Sen. Carl Levin (D) said: Read the rest of this entry »

Geneva Report on the World Economy: “Deleveraging, What Deleveraging?”

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September 29th, 2014

This report (written Luigi Buttiglione, myself, Lucrezia Reichlin and Vincent Reinhart) will be available here from 9am this morning.  The VOX summary article is here.  FT report here.

Update: I will present the report in a Policy Institute seminar on Thursday 2nd October, 12-1, in IIIS seminar room at TCD.