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BER1 revalues it to $1 billion (as an intangible asset under GAAP), and books gain in Bermuda (tax-free); An Irish subsidiary, IRL1, purchases this intangible asset from BER1, for $1 billion; Under the CAIA rules, IRL1 can write-off the $1 billion paid for this group intangible asset against Irish tax;
In addition the 2010 Transfer Pricing rules do not apply to Section 110 SPVs. [70] [43] Irish professional services have developed ways to link Irish Section 110 SPVs with Irish QIAIFs (or QIFs) to create an Orphaned Super–QIAIF. [71]
The discussion in this section explains an economic theory behind optimal transfer pricing with optimal defined as transfer pricing that maximizes overall firm profits in a non-realistic world with no taxes, no capital risk, no development risk, no externalities or any other frictions which exist in the real world.
The Fund Transfer Pricing (FTP) measures the contribution by each source of funding to the overall profitability in a financial institution. [1] Funds that go toward lending products are charged to asset-generating businesses whereas funds generated by deposit and other funding products are credited to liability-generating businesses.
Irish CT Revenues jump in 2015, the year of Apple's re-structure of its BEPS tools. [26] Since Apple's 2015 re-structure, Irish CT Revenue as a % of Total Irish Exchequer Tax Revenue is at its pre-crisis peak of over 16% (OECD average is 7.5%); [26] [27] Irish CT Revenue has been 10 to 16% of Total Irish Exchequer Tax Revenue (see graphic). [24]
President-elect Donald Trump has promised a major escalation of the nation’s tariffs. Trump has proposed tariffs of between 60% and 100% on Chinese goods, and a tax of between 10% and 20% on ...
They were used by U.S. distressed debt funds to avoid billions in Irish taxes, [124] [125] [126] assisted by Irish tax-law firms using in-house Irish children's charities to complete the orphan structure, [127] [128] [129] that enabled the U.S. distressed debt funds to export the gains on their Irish assets, free of any Irish taxes or duties ...
Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]