effective tax rates that are similar to those of prior U.S. tax inversions to Ireland (e.g. Medtronic). Companies taking advantage of Ireland's corporate tax regime are also threatened by the EU's desire to introduce EU–wide anti-BEPS tool regimes (e.g. the 2020 Digital Services Tax, and the CCCTB). Tax system Tax rates , there are two rates of corporation tax ("CT") in the Republic of Ireland: a 12.5% headline rate for trading income (or "active businesses income" in the Irish tax code); trading relates to conducting a business, not investment trading; a 25.0% headline rate for non-trading income (or also called passive income in the Irish tax code); covering investment income (e.g. income from buying and selling assets), rental income from real estate, net profits from foreign trades, and income from certain land dealings and income from oil, gas and mineral exploitations in Ireland. The 10% manufacturing relief tax scheme ended in 2010 (see graphic). Key aspects , the key attributes that tax experts note regarding the Irish corporate tax system are as follows: Low headline rate. At 12.5%, Ireland has one of the lowest headline tax rates in Europe (Hungary 9% and Bulgaria 10% are lower); OECD average is 24.9%. Transparent. Many of Ireland's corporation tax tools are OECD–whitelisted, and Ireland has one of the lowest secrecy scores in the 2018 FSI rankings. "Worldwide tax". Ireland is one of six remaining countries that use a "worldwide tax" system (Chile, Greece, Ireland, Israel, South Korea, Mexico). No "thin capitalisation". Ireland has no thin capitalisation rules, which means that Irish corporates can be financed with 100% debt, and 0% equity. Double Irish residency. Before 2015, Irish CT was based where a company was "managed and controlled" versus registered; the "Double Irish" ends in 2020. Single Malt residency. Post closure of the Double Irish to new entrants in 2015, it can be recreated by wordings in selective tax treaties (e.g. Malta and UAE). Extensive treaties. , Ireland has bilateral tax treaties with 73 countries (the 74th, Ghana, is pending). Holding company regime. Built for tax inversions, it gives Irish–based holding companies tax relief on withholding taxes, foreign dividends and CGT. Intellectual property regime. Built for the BEPS tools of U.S. technology and life sciences firms, recognises a wide range of intellectual assets that can be charged against Irish tax; the CAIA arrangement. Knowledge Development Box. Ireland created the first OECD–compliant KDB in 2016