 A "business plan" must be produced with Irish employment and salary levels that are acceptable to the Irish State during the period capital allowances are claimed.If the Irish subsidiary is wound up within 5 years, the CAIA intangible capital allowances are repayable, which is called "clawback".Irish BEPS tools are not overtly marketed as brochures showing near-zero effective tax rates ("ETR") would damage Ireland's ability to sign and operate bilateral tax treaties (i.e.