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Dutch Sandwich
Dutch Sandwich is a base erosion and profit shifting (BEPS) corporate tax tool, used mostly by U.S. multinationals to avoid incurring EU withholding taxes on untaxed profits as they were being moved to non-EU tax havens (such as the Bermuda black hole). These untaxed profits could have originated from within the EU, or from outside the EU, but in most cases were routed to major EU corporate-focused tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich. Explanation The structure relies on the tax loophole that most EU countries will allow royalty payments be made to other EU countries without incurring withholding taxes. However, the Dutch tax code allows royalty p ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Incorporation (business)
Incorporation is the formation of a new corporation. The corporation may be a business, a nonprofit organization, sports club, or a local government of a new city or town. In the United States Specific incorporation requirements in the United States differ on a state by state basis. However, there are common pieces of information that states require to be included in the certificate of incorporation. *Business purpose *Corporation name *Registered agent *Inc. *Share par value *Number of authorized shares of stock *Directors *Preferred shares *Officers *Legal address A business purpose describes the incorporated tasks a company has to do or provide. The purpose can be general, indicating that the budding company has been formed to carry out "all lawful business" in the region. Alternatively, the purpose can be specific, furnishing a more detailed explanation of the products and/or services to be offered by their company. The chosen name should be followed with a corporate iden ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Haven
A tax is a compulsory financial charge or some other type of levy imposed on a taxpayer (an individual or legal entity) by a governmental organization in order to fund government spending and various public expenditures (regional, local, or national), and tax compliance refers to policy actions and individual behaviour aimed at ensuring that taxpayers are paying the right amount of tax at the right time and securing the correct tax allowances and tax reliefs. The first known taxation took place in Ancient Egypt around 3000–2800 BC. A failure to pay in a timely manner ( non-compliance), along with evasion of or resistance to taxation, is punishable by law. Taxes consist of direct or indirect taxes and may be paid in money or as its labor equivalent. Most countries have a tax system in place, in order to pay for public, common societal, or agreed national needs and for the functions of government. Some levy a flat percentage rate of taxation on personal annual income, but mo ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Inversion
A tax inversion or corporate tax inversion is a form of tax avoidance where a corporation restructures so that the current parent is replaced by a foreign parent, and the original parent company becomes a subsidiary of the foreign parent, thus moving its tax residence to the foreign country. Executives and operational headquarters can stay in the original country. The US definition requires that the original shareholders remain a majority control of the post-inverted company. The majority of the less than 100 material tax inversions recorded since 1993 have been of US corporations (85 inversions), seeking to pay less to the US corporate tax system. The only other jurisdiction to experience a material outflow of tax inversions was the United Kingdom from 2007 to 2010 (22 inversions); however, UK inversions largely ceased post the reform of the UK corporate tax code from 2009 to 2012. The first inversion was McDermott International in 1983. Reforms by US Congress in 2004 hal ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Exporting
Tax exporting occurs when a country (or other jurisdiction) shifts its tax burden (partially) abroad. For example, if residents of country A hold shares of a company in country B, the government in B might want to levy an inefficiently high tax on this company's profits since the tax is partially borne by the shareholders in A. Tax exporting does not necessarily involve direct taxation of foreign residents. It can also work through other economic channels, such as price changes. See also * Capital flight * Capital strike * Luxembourg leaks * Tax avoidance * Tax competition * Tax inversion * Double Irish arrangement The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax ... References Further reading * * * * International taxation Tax {{tax-stub ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Offshore Financial Centre
An offshore financial centre (OFC) is defined as a "country or jurisdiction that provides financial services to nonresidents on a scale that is incommensurate with the size and the financing of its domestic economy." "Offshore" does not refer to the location of the OFC, since many Financial Stability Forum– IMF OFCs, such as Delaware, South Dakota, Singapore, Luxembourg and Hong Kong, are located "onshore", but to the fact that the largest users of the OFC are non-resident, i.e. "offshore". The IMF lists OFCs as a third class of financial centre, with international financial centres (IFCs), and regional financial centres (RFCs); there is overlap (e.g. Singapore is an RFC and an OFC). The Caribbean, including the Cayman Islands, the British Virgin Islands and Bermuda, has several major OFCs, facilitating many billions of dollars worth of trade and investment globally. During April–June 2000, the Financial Stability Forum–International Monetary Fund produced the first l ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Nature Research
Nature Portfolio (formerly known as Nature Publishing Group and Nature Research) is a division of the international scientific publishing company Springer Nature that publishes academic journals, magazines, online databases, and services in science and medicine. Nature Research's flagship publication is ''Nature'', a weekly multidisciplinary journal first published in 1869. It also publishes the ''Nature-''titled research journals, ''Nature Reviews'' journals (since 2000), society-owned academic journals, and a range of open access journals, including '' Scientific Reports'' and ''Nature Communications''. Springer Nature also publishes ''Scientific American'' in 16 languages, a magazine intended for the general public. In 2013, prior to the merger with Springer and the creation of Springer Nature, Nature Publishing Group's owner, Holtzbrinck Publishing Group, bought a controlling stake in Frontiers. Before Springer Nature was formed in 2015, Nature Research (as the Nature Publi ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Leprechaun Economics
Leprechaun economics was a term coined by economist Paul Krugman to describe the 26.3 per cent rise in Irish 2015 GDP, later revised to 34.4 per cent, in a 12 July 2016 publication by the Irish Central Statistics Office (CSO), restating 2015 Irish national accounts. At that point, the distortion of Irish economic data by tax-driven accounting flows reached a climax. In 2020, Krugman said the term was a feature of all tax havens. While the event that caused the artificial Irish GDP growth occurred in Q1 2015, the Irish CSO had to delay its GDP revision and redact the release of its regular economic data in 2016–2017 to protect the source's identity, as required by Irish law. Only in Q1 2018 could economists confirm Apple as the source, and that this was the largest ever base erosion and profit shifting (BEPS) action, and the largest hybrid–tax inversion of a U.S. corporation. The event marked the replacement of Ireland's prohibited BEPS tool, the Double Irish, with the ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Matheson (law Firm)
Matheson (previously Matheson Ormsby Prentice), is an Irish law firm partnership based in the IFSC in Dublin, which specialises in multinational tax schemes (e.g. for clients in Ireland such as Microsoft, Google and Abbot), and tax structuring of special purpose vehicles (e.g. Section 110 securitisation SPVs). Matheson is estimated to be Ireland's largest corporate law firm. Matheson state in the International Tax Review that their tax department is: "significantly the largest tax practice group amongst Irish law firms". Development While Matheson's website traces their history back to 1825 and notes that their offices were burnt in the Irish Easter Rising of 1916, it wasn't until after the creation and initial development of Dublin's International Financial Services Centre (or IFSC) that Matheson emerged as a small but standalone law firm with 14 partners and over 50 solicitors (or lawyers) in 1991. It moved to its current IFSC offices, 70 Sir John Rogerson's Quay ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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