Search results
Results from the WOW.Com Content Network
The earliest recorded versions of the Double Irish-type BEPS tools are by Apple in the late 1980s, [19] and the EU discovered Irish Revenue tax rulings on the Double Irish for Apple in 1991. [12] Irish state documents released to the Irish national archives in December 2018 showed that Fine Gael ministers in 1984 sought legal advice on how U.S ...
The Double Irish was the largest BEPS tool in history which by 2015, was shielding over US$100 billion in mostly US corporate profits from US taxation. When the EU Commission fined Apple €13 billion for using an illegal hybrid-Double Irish structure, their report noted that Apple had been using the structure from at least as far back as 1991 ...
The U.S. administration condemned Apple's Irish tax structures in the 2013 Levin–McCain PSI, [59] [60] [61] however, it came to Apple's defense when the EU Commission levied a €13 billion fine on Apple for Irish tax avoidance from 2004 to 2014, the largest corporate tax fine in history, arguing that Apple paying the full 12.5% Irish ...
Single Malt – takes the Double Irish tax-residence concept around "management and control", and worded directly into specific bilateral tax treaties (Malta, UAE). [156] Capital Allowances for Intangible Assets – introduced in the 1997 TCA but expanded in the 2009 Finance Act, [11] and made tax-free in the 2015 Finance Act for Apple. [u] [178]
The Irish tax code considers IRL2 a Bermuda company (used the "managed and controlled" test), but the US tax code considers IRL2 an Irish company (uses the registration test). Neither taxes it. Apple's subsidiary, ASI, behaved like it was IRL2, it was "managed and controlled" via ASI Board meetings in Bermuda, so Irish Revenue did not tax it.
An American woman who previously posed as heiress to a fortune faces extradition to Northern Ireland to face charges in connection with alleged schemes in which she is accused of duping investors ...
Tax evasion, on the other hand, is the general term for efforts by individuals, corporations, trusts and other entities to evade taxes by illegal means. Both tax evasion and some forms of tax avoidance can be viewed as forms of tax noncompliance, as they describe a range of activities that are unfavourable to a state's tax system. [11]
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 ...