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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 ...
Double Irish arrangements have allowed multinational companies to avoid taxes owed to countries in which foreign subsidiaries of a U.S.-based multinational corporation are incorporated. Repatriation tax avoidance strategies, however, have allowed U.S.-domiciled companies to avoid owing taxes to the United States.
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 ...
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.
The Dutch Sandwich is most commonly associated with the double Irish BEPS tax structure, [1] [2] and Irish-based US technology multinationals such as Google. [15] [16] The Double Irish is the largest BEPS tool in history, helping mostly US technology and life sciences multinationals shield up to US$100 billion per annum from taxation.
(April 2013) Click [show] for important translation instructions. View a machine-translated version of the German article. Machine translation, like DeepL or Google Translate , is a useful starting point for translations, but translators must revise errors as necessary and confirm that the translation is accurate, rather than simply copy ...
Apple's Q1 2015 Irish quasi–tax inversion of US$300 billion in IP, is the largest BEPS transaction in history, and double the blocked 2016 USD 160 billion Pfizer–Allergan Irish inversion. [11] Irish secrecy laws prevented the transaction from being confirmed until January 2018, and was labelled " Leprechaun economics " by Nobel Prize ...
In November 2017, Irish economist David McWilliams writing in The Irish Times quoted that the U.S. BEA statistics implied U.S. multinationals in Ireland paid an effective tax rate of 3.27% on Irish registered pre-tax income of $106,789 million in 2013, and 3.38% on Irish registered pre-tax income of $108,971 million in 2014, due to "a myriad of ...