 it must be "confidential" as higher-tax locations would not sign full tax treaties with locations like Bermuda), the Capital Allowances for Intangible Assets ("CAIA") BEPS tool (also called the Green Jersey), enables Ireland to act as the terminus for the untaxed profits (e.g.Ireland becomes Bermuda, a "Sink OFC").The CAIA uses the accepted tax concept of providing capital allowances for the purchase of assets.