tax haven); and has valued the assets for the inter-Group transaction using an Irish IFSC accounting firm. CAIA capitalises the tax shield of the Double Irish, and thus materially increases the distortion of the Irish national accounts. This was shown in July 2016 when the Irish CEO had to restate Irish 2015 GDP by 34.4% due to Apple's Q1 2015 restructure into a CAIA BEPS tool. A June 2018 report by the EU Parliament's GUE–NGL body showed that Apple doubled the Irish corporate tax shield of its CAIA BEPS tool by financing the acquisition of the IP via Jersey (the report called the CAIA BEPS tool, the Green Jersey). Whereas the Double Irish and Single Malt have an ETR of less than 1%, the ETR of the CAIA BEPS tool ranges from 0% to 2.5% depending on the date on which the CAIA tool was started (see effective tax rates). Knowledge Development Box Ireland created the first OECD–compliant 'Knowledge Development Box' ("KDB"), in the 2015 Finance Act, to further support its intellectual property BEPS toolkit. The KDB behaves like a CAIA BEPS scheme with a cap of 50% (i.e. similar to getting 50%–relief against capitalised IP, for a net effective Irish tax rate of 6.25%). As with the CAIA BEPS scheme, the KDB is limited to specific "qualifying assets", however, unlike the CAIA tool, these are quite narrowly defined by the 2015 Finance Act. The Irish KDB was created with tight conditions to ensure OECD compliance and thus meets the OECD's "modified Nexus standard" for IP. This has drawn criticism from Irish tax advisory firms who feel that its use is limited to pharmaceutical (who have the most "Nexus" compliant patents/processes), and some niche sectors. It is expected these conditions will be relaxed over time through refinements of the 2015 Finance Act; a route taken by other Irish IP–based BEPS tools: Double Irish – the unusual definition of tax residence was embedded in the 1997 Taxes and Consolidation Act (TCA), and expanded in 1999–2003 Finance Acts. Single Malt – takes the Double Irish tax-residence concept around "management and control", and worded directly into specific bilateral tax treaties (Malta, UAE). Capital Allowances for Intangible Assets – introduced in the 1997 TCA but expanded in the 2009 Finance Act, and made tax-free in the 2015 Finance Act for Apple. Section 110 SPVs – created in the 1997 TCA with strong anti-avoidance controls,