In an obscure regulatory filing in Washington some weeks ago, US pharmaceutical giant Pfizer did something it had never done before: it declared publicly the amount of corporation tax it pays to Revenue in Dublin. The 2025 payment was not far off €900 million, a huge sum for a single year.
Pfizer has been in Ireland since 1969, operating without fanfare until the blockbuster anti-impotence drug Viagra raised its profile and changed its fortunes. These days the company employs more than 4,500 staff in Grangecastle and Ringsend in Dublin, Ringaskiddy in Cork and Newbridge, Co Kildare.
Although Pfizer was always assumed to be a major taxpayer in Ireland, the extent of its actual payments was never disclosed publicly. Pfizer’s extensive Irish business is buried within the financial accounts of the Dutch entity that manages its European operations – CP Pharmaceuticals International – and company filings to the US Securities & Exchange Commission (SEC), which did not previously break down tax payments between different locations.
All that has changed this year, with new US regulations taking force that compel large companies to declare most tax payments on a country-by-country basis. Under an accounting standard known as ASU 2023-09, American groups paying more than 5 per cent of their corporation tax in any single jurisdiction outside the US must set out the payments in public reports. The requirements embrace taxes paid, net of any refunds, so the figures represent actual cash transfers.
RM Block
Such rules, designed to boost transparency, apply to annual 10-K reports filed to the SEC after December 2025. In practice this means companies such as Pfizer, with a fiscal year matching the calendar year, have already started to declare country-by-country payments.
The 10-K filing from Pfizer at the end of February shows its Irish tax bill in 2025 was $1.02 billion (€870 million), more than a quarter of its total $4.69 billion corporate tax bill and enough to make it one of the biggest taxpayers in the State. Pfizer, like other companies contacted for this piece, did not comment on its Irish tax payments.
It is now clear that ASU 2023-09 has changed the ground rules. In addition to Pfiizer, a cascade of recent SEC filings casts new light on Irish tax payments by drug groups Regeneron, which paid $645.2 million, and Johnson & Johnson, which paid $600 million. AbbVie paid $431 million and Bristol Myers Squibb paid $179 million. Among big tech groups, the social media giant Meta, owner of Facebook, Instagram and WhatsApp, paid $567 million. Tech company Salesforce paid $92 million in the year to January, down from $139 million in the previous trading period.
Such companies are clients of IDA Ireland, the State inward investment agency, which has hundreds of US clients on its books. “IDA Ireland has no comment in relation to this matter,” the agency said in reply to questions about the release into the open of company tax payments.
Controversy
Ireland’s business-friendly tax regime and low 12.5 per cent tax rate were long a matter of controversy in the US and the European Union before the decision to apply a 15 per cent rate on very large corporations under the OECD overhaul of global tax rules.
The regime remains highly sensitive in Ireland’s foreign relations, all the more so in the light of Donald Trump’s “America first” mantra as US president. Although he is preoccupied right now with war in the Middle East, Trump tends to hit out at will at anything he perceives to be against US interests. There is quiet concern in Government and business circles that the disclosure of big Irish tax payments by American companies could stir a White House backlash.
“It publicises more that we’re dependent on named companies. It makes it all very real, less theoretical,” says a senior Dublin figure familiar with tax policy, speaking on condition of anonymity.
“What it does do is it puts us in the spotlight. It puts in the crosshairs for Trump. That’s not a great place to be because when you’re explaining you’re losing ... the Americans are very fixated on it.”
Such sentiments were echoed by a high-level member of the business community, who has dealings with many multinational investors. The extent of Irish tax payments by individual companies showed they were “material” both for the exchequer but also to the US authorities, the person says. “This is real.”
All of this comes amid questions over the sustainability of rapid growth in Ireland’s corporation tax receipts, which have quadrupled in a decade and rose 17 per cent in 2025 to reach €32.9 billion. Now the second-biggest source of exchequer funds behind income tax, such revenues are forecast to advance to about €35 billion in 2026.
The “windfall” element of corporation tax receipts are estimated this year to amount to €20 billion. This means, in effect, that a very large portion of the tax take is not directly linked to domestic activity and may therefore be transitory. In essence, corporation tax payments have advanced so quickly that it has led to fears they could fall just as quickly.
The case of Google owner Alphabet appears to illustrate this point. Ireland was long a big tax centre for the company, but Alphabet’s recent 10-K does not directly cite specific tax payments in Dublin. The only non-US jurisdiction for which corporation tax payments were set out was Brazil. This suggests payments from Alphabet’s Irish unit did not exceed 5 per cent of the group’s total $21.5 billion tax liability in 2025. Alphabet had no comment.
The company’s current arrangements contrast with Google’s controversial “double-Irish” tax avoidance mechanism of the past, which prompted intense international criticism. The then government closed the scheme to new entrants from 2015 but existing arrangements could remain until the end of 2020. Google scrapped the structure after 2019.
`Concentration risks’
Threats to Ireland’s corporation tax income have evolved and intensified since those days, not least because the three largest taxpaying companies now contribute some 46 per cent of the receipts.
“Concentration risks mean that there are individual decisions by companies that could have very significant impacts on the public finances overall,” says Dermot O’Leary, chief economist at Goodbody stockbrokers.
Recent Goodbody research for the Irish Pharmaceutical Healthcare Association – the trade group for drug companies – found the pharma sector “accounted for 18 per cent of total corporation taxes in 2023”.
However, ASU 2023-09 data has now changed the picture. “Since that report was published – and it was only published in March – we have had more information about taxes paid by the sector in 2025, with the sector [now] estimated to account for over a quarter of corporation revenues in 2025,” O’Leary says.
This is the Irish backdrop to the American accounting rule, which puts responsibility on companies themselves to disclose their payments. It marks a new departure as Revenue never discloses who pays what to the exchequer. Under the Taxes Consolidation Act of 1997, the State’s tax authority is expressly precluded from comment on the affairs of any business, individual or entity – or any interactions with them.
What is more, the depth and breadth of business reporting to the Companies Registration Office (CRO) varies widely. Some groups shield their affairs behind unlimited corporate structures in which there is often no requirement at all to publicly file any accounts. Irish data can also be obscured in accounts for intermediate parent or ultimate parent companies, often to the extent that nothing meaningful is disclosed. Other groups develop opaque structures with so many subsidiaries that it is impossible to gauge the performance and tax liabilities of their Irish units.
Still, there are exceptions. CRO filings for Apple Operations International, the main Irish unit of the iPhone manufacturer, show it paid $12.078 billion in corporation tax in the year to September 2025.
The level of actual cash payments to Ireland per ASU 2023-09 rules is unlikely to be disclosed until Apple’s next 10-K filing in October.
Even when setting aside the impact of the €14 billion-plus in Apple tax payments to Ireland after the 2024 European court ruling on illegal state aid, the company is widely perceived to be the biggest single taxpayer. After all, Apple’s Irish operation is the umbrella for most of its non-US business around the world.
The other two largest payments are reckoned to come from drug company Eli Lilly and Microsoft, the software and consumer electronics collosus.
Eli Lilly has some 3,700 staff in Ireland, with big manufacturing operations in Limerick and Kinsale, Co Cork, and a global business solutions division in Little Island, Cork. Blockbuster products such as Zepbound and Mounjaro have taken the company into the vanguard of the revolution in weight-loss drugs, supercharging profits and tax payments from its Irish manufacturing hub.
Eli Lilly’s 10-K in February showed a corporation tax payment to Ireland of $6.6 billion in 2025, double the $3.3 billion the company paid to the US federal government.
“Cash payments of income taxes increased $4.3 billion in 2025 compared with 2024, driven primarily by a $4.2 billion increase in Ireland resulting from higher production activity to meet growing global demand for our medicines and a prior year tax payment,” says the 10-K report.
“At December 31, 2025 and 2024, prepaid expenses included prepaid taxes of $12.9 billion and $7.1 billion, respectively. Prepaid taxes largely reflect taxes paid on intercompany profit not yet recognised, primarily related to Ireland.”
Eli Lilly had no comment in reply to questions about such figures but the scale of Irish tax payments vis-a-vis the US is striking.
Microsoft’s next 10-K is not due for release until July. Still, the last 10-K shows Microsoft’s Irish operation represented 81 per cent of its $54.42 billion non-US pretax profit in the year to June 2025. At the same time, filings by individual Microsoft companies in Ireland show tax payments counted in billions of dollars. Microsoft Ireland Research paid €5.436 billion in corporation tax in the June 2025 fiscal year, and Microsoft Ireland Operations paid $841.36 million.
`Risks’
Ireland’s corporation tax income is strong, growing and founded in business activity that employs many thousands of workers. But this new flow of data underlines the extent to which individual companies now contribute huge volumes of tax revenue quantified every year in billions and hundreds of millions of euro.
In a report this week, the European Commission said Irish tax revenues were exposed “to significant sectoral and even firm-specific” risks. “The same foreign-owned multinationals are among the largest contributors to personal income tax, which further compounds the risks to revenue stability,” it added.
The International Monetary Fund struck a similar tone last week, saying the tax base should be broadened “to reduce reliance on highly concentrated” corporate income tax.
In summary, the more cash that comes in the greater the downside risks. These are associated with the performance of individual companies and markets, inevitable fluctuations in the economic and innovation cycle, and volatility in geopolitics and the trade arena in Trump’s second term.
“If the tide goes out with one or two of those companies or there’s a problem with the drug [they sell] or another company has a getter drug then we could be in trouble,” says one person in Government circles.
“What happens if and when our friend in the White House sees these numbers? Does he call them in?”
That remains to be seen.
