points" have been the young, English-speaking, flexible workforce, a strong educational system, commercially-aware third level institutions, a location which allows easy exporting into Europe, and the ability to tap into European talent in the wake of Brexit, and a 'clustering effect' in certain industrial and business sectors. Criticisms Narrow base The IDA is strongly reliant on the U.S. as a source of FDI. There are no non-U.S./non-U.K. firms in Ireland's top 50 firms (by revenue), and only one by employees, the German retailer Lidl. The 14 foreign multinationals in Ireland's top 20 firms are all U.S-based (including tax inversions). The U.K. firms in Ireland, outside of retailers like Tesco who sell into Ireland (also like Lidl), are pre-2009 after which the U.K. changed its tax code (see U.K. transformation). Taxation Up until 2018, the U.S. was one of the last few global jurisdictions not to run a "territorial" tax system (the U.K. switched in 2009–12). Jurisdictions with "territorial" tax systems have separate, and much lower, tax rates for foreign-sourced profits, and companies from such places therefore make less use of Ireland as a base. While the IDA market Ireland as a base from which to sell into Europe, Despite other features, some commentators see Ireland as a base for U.S. multinationals to shield themselves from the pre-TCJA “worldwide” tax system (Ireland is sometimes described as a corporate haven). U.S. multinationals aside, Ireland's main attractiveness is for life sciences manufacturing, who have an optimal combination of intellectual property and tangible assets to use Ireland's main IP-based BEPS tool, the capital allowances for intangible assets scheme (which has an Irish effective tax rate of <3%). A key IDA Ireland target market is Japan, which is a large global source of life sciences manufacturing enterprises, and also has one of the highest corporate tax rates in the world. Brexit The IDA has listed managing Brexit as a priority in the coming years. Ireland has been criticised for failing to win substantive London business, and particularly the valuable financial services business, as a result of Brexit. However, the IDA has been credited with achieving limited success in the face of housing and infrastructure shortages and regulatory hurdles, and a 2018 S&P Global Market Intelligence study found that Germany and Ireland were the leaders in attracting financial businesses relocating from London. In the Irish government's 2019 budget, IDA Ireland was allocated €2 million for the