 Thus, with the addition of IRL2 and DUT1, we have the "Double Irish dutch sandwich" tax structure.In 2010, the Irish State, on lobbying from PwC Ireland's IFSC tax partner, Feargal O'Rourke, relaxed the rules for sending royalty payments to non–EU countries without incurring Irish withholding tax (thus ending the dutch sandwich), but they are subject to conditions that will not suit all Double Irish arrangements.The 2014–16 EU investigation into Apple in Ireland (see below), showed that the Double Irish existed as far back as 1991.