regarded that Ireland's main TP–based BEPS tool users are the life sciences manufacturers. Effective tax rate (ETR) Background The headline tax rate is the rate of taxation that is applied to the profits that a tax-code deems to be taxable after deductions. The effective tax rate is the rate of taxation implied by the actual quantum of tax paid versus profits before all deductions are applied. The gap between the Irish corporate headline rate of 12.5%, and the much lower Irish corporate effective rate of 2–4%, is a source of controversy: The Irish State asserts Ireland's ETR similar to the Irish headline CT rate of 12.5%. This is an important issue as Ireland's BEPS tools, the core of Ireland's , rely on having a global network of full bilateral tax treaties that accept Ireland's BEPS tools; major economies do not sign full bilateral tax treaties with known tax havens (e.g. Bermuda or Jersey). When the EU Commission published their findings on Apple's Irish BEPS tools in 2016 (see below), Brazil became the first G–20 economy to blacklist Ireland as a tax haven, and suspended the Brazil–Ireland bilateral tax treaty. In 2014, Ireland refused to implement the 2013 EU Accounting Directive, and invoked exemptions on reporting holding company structures until 2022, so that multinationals can register as Irish "unlimited liability companies" (ULCs), which do not have to file public accounts with the Irish CRO. However, as most foreign multinationals in Ireland are major U.S. listed companies (see Table 1), tax academics have been able to estimate their Irish ETR from U.S. filings. In addition, the 2014–2016 EU investigation into Apple, Ireland's largest company, produced detail on Apple's Irish ETR from 2004 to 2014. Independent research Notable independent research from 1994 to 2018, has estimated Ireland's overall aggregate effective tax rate for foreign corporates at between 2.2% to 4.5%: Filed accounts Over the years, the largest U.S. multinationals in Ireland, who are both Ireland's largest companies and pay most of Ireland's corporation tax (see low tax economy), have filed various accounts showing their Irish ETR. As discussed above, because Ireland refused to ratify the 2013 EU Accounting Directive, many of these multinationals have switched to "unlimited liability companies" in Ireland, which do not file accounts; thus the information is only available in a few cases. However, where U.S. multinationals have disclosed Irish financials, they all imply an Irish ETR of less than