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Ireland vs Delaware (USA): which jurisdiction wins?

Ireland vs Delaware (USA) — both credible, very different trade-offs. Below: side-by-side on the variables that actually move the decision.

 IrelandDelaware (USA)
Tax headline12.5% trading, 15% Pillar 2 for large groups21% federal + 8.7% Delaware (no state tax on non-DE income)
Formation days51
First-year cost$5,500$1,200
Treaties75+70+
SubstanceSubstance critical (CFC, BEPS)US tax presence considerations
BankingBOI, AIB, plus US bank branchesMercury, Brex, plus tier-1 US banks

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