targeted at Irish BEPS tools as used by U.S. multinationals in Ireland. The TCJA introduces many of the changes that the UK made to its tax code in 2009–2012, including moving to a "territorial tax" system and reduction of headline rate of tax; the UK changes reversed many of the UK corporate tax inversions to Ireland. However the TCJA goes even further and the GILTI–FDII–BEAT tax regime are a more severe "carrot and stick" to encourage U.S. multinationals to re-locate their substantive operations (and IP), back to the U.S. However, the TCJA is large and complex, and in 2018, tax experts have noted that errors and flaws in the TCJA, could be a "boom for Ireland", over the next few years. Sustainability of system The above post–2009 UK, EU and U.S. countermeasures against Ireland's corporate tax system, and by extension Ireland's economic model, have been a cause of concern in Ireland, and even the "architect" of Ireland's BEPS tools, PricewaterhouseCoopers tax-partner, Feargal O'Rourke, has warned on the sustainability of Irish CT revenues. In December 2017, the Irish Government published a study on the sustainability of its corporate tax system by University College Cork economist Seamus Coffey (called the Coffey Report). Coffey reported that Irish CT revenues were sustainable to 2020, but caveated that given the concentration of CT revenues to a handful of U.S. multinationals, a shock to CT revenues was "inevitable". In Q2 2018, an IMF country report on Ireland, while noting the significant exposure of Ireland's economy to U.S. corporates, concluded that the TCJA may not be as effective as Washington expects in countering Ireland as a U.S. corporate tax haven. In writing its report, the IMF conducted confidential anonymous interviews with Irish corporate tax experts. However, in June 2018, the former IMF mission-chief for Ireland Ashoka Mody, who oversaw Ireland's bailout during the 2009–2012 Irish financial crisis, warned that in relation to TCJA: Historical rates (1994–2018) The following are the historical rates of Irish corporation tax since 1994. A 'special rate' of 10% for companies in manufacturing (and the Shannon Free Zone), was introduced in 1980–81 (with EU State-aid approval), and extended to the financial services in the International Financial Services Centre (IFSC) zone in 1987 (with EU State-aid approval); due to EU decision to withdraw EU State-aid approval in 1996–1998, the special rate was phased-out and ended on 31 December 2003 for new schemes, with expiry