the U.S. tax code in 2016 stopped further U.S. interest in Shire plc, and in 2018, it accepted a lower bid from Japanese pharmaceutical multinational Takeda, who will not be using Shire plc to invert to Ireland. Experian plc – the first UK corporate tax inversion to Ireland in 2016, however almost all of Experian's business is U.S.–based, so it is unlikely to return to the UK. Tesco (Ireland) Tesco is not in Ireland for any tax-related reason; Tesco (Ireland) is the Irish holding company for Tesco plc's large network of Irish grocery stores. EU countermeasures (1996–2018) While national tax policy is excluded from EU treaties, the EU has challenged Ireland's tax code under State-aid legislation. Seamus Coffey's 2016 Review of Ireland's Corporation Tax Code chronicled how the EU withdrew the exemption from State-aid rules for Ireland's special tax rate of 10% in 1996–1998, however, Ireland countered the EU withdrawal by lowering the entire Irish standard rate of corporate tax from 40% to 12.5% over 1996–2003 (see ). In October 1994, the Financial Times chronicled how the EU Commission forced the closure of the Double Irish BEPS tool in 2015 on the threat of a full State-aid investigation into Ireland's tax code. However, Ireland won a concession from the EU to allow existing users of the Double Irish (e.g. Google, Facebook, Microsoft) to keep using it until 2020, and developed replacement BEPS tools, namely the Single Malt and CAIA BEPS tools. In August 2016, the EU Commission levied the largest corporate tax fine in history, on Apple's Irish Double Irish BEPS tool from 2004 to 2014, using State-aid rules. In January 2017, the EU Commissioner for Taxation, Pierre Moscovici, explicitly stated to an Irish State Oireachtas Finance Committee that "Ireland is not a tax haven"; however, in January 2018 Moscovi called Ireland and the Netherlands "tax black holes". In January 2018, Ireland was accused of "tax dumping" by German political leaders. In March 2018, the EU Commission proposed a "Digital Services Tax" (DST), targeted at U.S. technology firms using Irish BEPS tools. The DST is designed to "override" Ireland's BEPS tools and force a minimum level of EU tax on U.S. technology firms. The EU have proposed the DST should be a 3% tax on revenues which would translate into an effective 10–15% tax rate (using pre-tax margins of 20–30% for Apple, Google and Microsoft); it is also expensible against