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Ireland As A Tax Haven
Ireland has been labelled as a tax haven or corporate tax haven in multiple financial reports, an allegation which the state has rejected in response. Ireland is on all academic " tax haven lists", including the , and tax NGOs. Ireland does not meet the 1998 OECD definition of a tax haven, but no OECD member, including Switzerland, ever met this definition; only Trinidad & Tobago met it in 2017. Similarly, no EU–28 country is amongst the 64 listed in the 2017 EU tax haven blacklist and greylist. In September 2016, Brazil became the first G20 country to "blacklist" Ireland as a tax haven. Ireland's base erosion and profit shifting (BEPS) tools give some foreign corporates ' of 0% to 2.5% on global profits re-routed to Ireland via their tax treaty network. Ireland's ''aggregate '' for foreign corporates is 2.2–4.5%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit. Ireland's ta ...
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OECD Hierarchy Of Taxes
The Organisation for Economic Co-operation and Development (OECD; , OCDE) is an intergovernmental organization with 38 member countries, founded in 1961 to stimulate economic progress and world trade. It is a forum whose member countries describe themselves as committed to democracy and the market economy, providing a platform to compare policy experiences, seek answers to common problems, identify good practices, and coordinate domestic and international policies of its members. The majority of OECD members are generally regarded as developed countries, with high-income economies, and a very high Human Development Index. their collective population is 1.38 billion people with an average life expectancy of 80 years and a median age of 40, against a global average of 30. , OECD Member countries collectively comprised 62.2% of global nominal GDP (USD 49.6 trillion) and 42.8% of global GDP (Int$54.2 trillion) at purchasing power parity. The OECD is an official United Nat ...
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Irish Section 110 Special Purpose Vehicle (SPV)
An Irish Section 110 special purpose vehicle (SPV) or section 110 company is an Irish tax resident company, which qualifies under ''Section 110'' of the '' Irish Taxes Consolidation Act 1997'' (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties. Section 110 was created in 1997 to help International Financial Services Centre (IFSC) legal and accounting firms compete for the administration of global securitisation deals, and by 2017 was the largest structured finance vehicle in EU securitisation. Section 110 SPVs have made the IFSC the third largest global Shadow Banking OFC. While they pay no Irish tax, they contribute €100 million annually to the Irish economy in fees paid to IFSC legal and accounting firms. In June 2016, it was discovered that US distressed debt funds used Section 110 SPVs, structured by IFSC service firms, to avoid Irish taxes on €80 billion of Irish domestic investments. ...
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Offshore Magic Circle
The offshore magic circle is the set of the largest multi-jurisdictional law firms who specialise in offshore financial centres, especially the laws of the British Overseas Territories of Bermuda, Cayman Islands, and British Virgin Islands, and the Crown dependencies of Jersey, Guernsey and The Isle of Man. The same firms are also increasingly advising on the laws of onshore financial centres, especially Ireland and Luxembourg. Definition The term is a derivation of the widely recognised London ' magic circle' of top law firms, and is widely used in the offshore legal industry. The term has also become used to describe the offshore legal industry in a more pejorative sense (e.g. when the general media reports on Paradise Papers–type offshore financial scandals), and is therefore more sparingly used, or found, in major legal publications (e.g. ''Legal Business''). There is no consensus definition over which firms belong in the offshore magic circle. A 2008 article in the pu ...
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ICAV
Qualifying Investor Alternative Investment Fund or QIAIF is a Central Bank of Ireland regulatory classification established in 2013 for Ireland's five tax-free legal structures for holding assets. The Irish Collective Asset-management Vehicle or ICAV is the most popular of the five Irish QIAIF structures, it is the main tax-free structure for foreign investors holding Irish assets. In 2018, the Central Bank of Ireland expanded the Loan Originating QIAIF or L–QIAIF regime which enables the five tax-free structures to be used for closed-end debt instruments. The L–QIAIF is Ireland's main debt–based BEPS tool as it overcomes the lack of confidentiality and tax secrecy of the Section 110 SPV. It is asserted that many assets in QIAIFs and LQIAIFs are Irish assets being shielded from Irish taxation. Irish QIAIFs and LQIAIFs can be integrated with Irish corporate base erosion and profit shifting ("BEPS") tax tools to create confidential routes out of the Irish tax system ...
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HMRC
His Majesty's Revenue and Customs (commonly HM Revenue and Customs, or HMRC, and formerly Her Majesty's Revenue and Customs) is a Departments of the United Kingdom Government, department of the UK government responsible for the tax collection, collection of Taxation in the United Kingdom, taxes, the payment of some forms of Welfare state in the United Kingdom, state support, the administration of other regulatory Regime#Politics, regimes including the national minimum wage and the issuance of national insurance numbers. HMRC was formed by the merger of the Inland Revenue and HM Customs and Excise, which took effect on 18 April 2005. The department's logo is the Tudor Crown (heraldry), Tudor Crown enclosed within a circle. Departmental responsibilities The department is responsible for the administration and collection of direct taxes including Income Tax, United Kingdom corporation tax, Corporation Tax, Capital Gains Tax (CGT) and Inheritance Tax (IHT), indirect taxes includ ...
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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. In United States federal legislation, US federal legislation a company which has been restructured in this manner is referred to as an inverted domestic corporation, and the term "corporate expatriate" is also used, for example in the Homeland Security Act of 2002. 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 inv ...
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Lidl
Lidl ( ) is a trademark, used by two Germany, German international discount supermarket, discount retailer chain store, chains that operates over 12,600 stores. The ''LD Stiftung'' operates the stores in Germany and the ''Lidl Stiftung & Co. KG'' in 30 other countries. ''LD Stiftung'' is headquartered in Bad Wimpfen and the ''Lidl Stiftung & Co. KG'' in Neckarsulm. Both sister companies belong to the Schwarz Group, which also includes hypermarket chain Kaufland. Lidl is the chief competitor of the German discount chain Aldi in several markets. History In 1930, Josef Schwarz became a partner in a company based in Heilbronn named ''Südfrüchte Großhandlung Lidl & Co.'' which had been established by Anton Lidl since at least 1858 under the name ''A.Lidl & Cie'' specialising in the sale of exotic fruits. Schwarz renamed the company ''Lidl & Schwarz KG'' and expanded into a food wholesaler. In 1977, under his son Dieter Schwarz, the Schwarz Group began to focus on discount m ...
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Table 1
Table may refer to: * Table (database), how the table data arrangement is used within the databases * Table (furniture), a piece of furniture with a flat surface and one or more legs * Table (information), a data arrangement with rows and columns * Table (landform), a flat area of land * Table (parliamentary procedure) * Table (sports), a ranking of the teams in a sports league * Tables (board game) * Mathematical table * Tables of the skull, a term for the flat bones * Table, surface of the sound board (music) of a string instrument * ''Al-Ma'ida'', the fifth ''surah'' of the Qur'an, occasionally translated as “The Table” * Calligra Tables, a spreadsheet application * Water table See also * Spreadsheet, a computer application * Table cut, a type of diamond cut * The Table (other) * Table Mountain (other) * Table Rock (other) * Tabler (other) * Tablet (other) Tablet may refer to: Medicine * Tablet (pharmacy), a mixture of pharmac ...
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Green Jersey
In road bicycle racing (e.g. Grand Tour stage races), the green jersey is a distinctive racing jersey worn by the most consistent highest finisher in the competition. While the overall race leader in the Tour de France will wear the yellow jersey, or "maillot jaune", the green jersey ("maillot vert") will be worn by the leader in the points competition. Since 2009, the Vuelta a España has also used the green jersey to signify the leader of the points competition. In the Giro d'Italia, the green jersey was, from 1974 to 2011, worn by the King of the Mountains, the leader in the competition for climbing specialists. Classification guide The following events use the "green jersey" to signify the current leader and/or final winner of the overall classification by points (often known as the sprinters' competition): * Tour de France (known as the "maillot vert") (see also Points classification in the Tour de France) * Vuelta a España * Critérium du Dauphiné Libéré * Tour ...
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Medtronic
Medtronic plc is an American-Irish medical device company. The company's legal and executive headquarters are in Republic of Ireland, Ireland, while its operational headquarters are in Minneapolis, Minneapolis, Minnesota. Medtronic rebased to Ireland following its acquisition of Irish-based Covidien in 2015. While it primarily operates in the United States, it operates in more than 150 countries and employs over 90,000 people. It develops and manufactures healthcare technologies and therapies. It is one of the biggest medical tech companies in the world and is currently the largest medical device company in the world by revenue. The company has developed several world-first technologies since its inception, including wearable and implantable pacemakers, the implantable cardioverter defibrillator, and remote monitoring systems. They also created miniaturized devices like the world's smallest pacemaker and spinal cord stimulator. History Medtronic was founded in 1949 in Minne ...
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Pfizer
Pfizer Inc. ( ) is an American Multinational corporation, multinational Pharmaceutical industry, pharmaceutical and biotechnology corporation headquartered at The Spiral (New York City), The Spiral in Manhattan, New York City. Founded in 1849 in New York by German entrepreneurs Charles Pfizer (1824–1906) and Charles F. Erhart (1821–1891), Pfizer is one of the oldest pharmaceutical companies in North America. Pfizer develops and produces medicines and vaccines for immunology, oncology, cardiology, endocrinology, and neurology. The company's largest products by sales are the Pfizer–BioNTech COVID-19 vaccine ($11 billion in 2023 revenues), apixaban ($6 billion in 2023 revenues), a pneumococcal conjugate vaccine ($6 billion in 2023 revenues), palbociclib ($4 billion in 2023 revenues), and tafamidis ($3 billion in 2023 revenues). In 2023, 46% of the company's revenues came from the United States, 6% came from Japan, and 48% came from other countries. Pfizer has been a publi ...
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Tax Foundation
The Tax Foundation is an international research think tank based in Washington, D.C. that collects data and publishes research studies on Taxation in the United States, U.S. tax policies at both the federal and state levels. Its stated mission is to "improve lives through tax policy research and education that leads to greater economic growth and opportunity". The Tax Foundation is organized as a 501(c)(3) Tax exemption, tax-exempt Non-profit organization, non-profit educational and research organization, with three primary areas of research: the Center for Federal Tax Policy, the Center for State Tax Policy, and the Center for Global Tax Policy. The group is known for its annual reports such as the ''State Tax Competitiveness Index'', ''International Tax Competitiveness Index'', and ''Facts & Figures: How Does Your State Compare'', which was first produced in 1941. History The Tax Foundation was organized on December 5, 1937, in New York City by Alfred P. Sloan Jr., Chai ...
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