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The Double Irish and Single Malt BEPS tools enable Ireland to act as a confidential "Conduit OFC" rerouting untaxed profits to places like Bermuda (e.g. it must be confidential as higher-tax locations would not sign full tax treaties with locations like Bermuda), the Capital Allowances for Intangible Assets (CAIA) BEPS tool (also called the ...
The Double Irish uses an Irish company (IRL2) that is legally incorporated in Ireland, and thus the US-tax code regards it as foreign, but is "managed and controlled" from, say, Bermuda (and thus the Irish tax code also regards it as foreign). The Dutch Sandwich, with the Dutch company as the "dutch slice" in the "sandwich", is used to move ...
The issue was Apple's variation of the Double Irish tax system, which, from 2004 to 2014, Apple used to shield €110.8 billion [10] [11] of non–US profits from tax. [12] On 9 January 2015, Apple informed the Commission [a] that it closed its hybrid–Double Irish, base erosion and profit shifting (BEPS) tool. [13]
Business One has engaged in tax evasion, which is ... the expressions "legal avoidance" and "illegal evasion", to make the meaning clearer. ... Double Irish ...
EU Commission's outline of Apple's hybrid–double Irish BEPS tax structure in Ireland, that used two branches inside a single company based on private rulings from the Irish Revenue Commissioners in 1991 and 2007. [214] Margrethe Vestager European Commissioner for Competition who led case SA:38373 on illegal State aid to Apple in Ireland (2004 ...
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 last two tax evasion penalties are on the severe end of the spectrum. The difference between civil and criminal fraud is the degree of proof required. In civil fraud cases, the government must ...
Single malt is another BEPS tax scheme designed to replicate the double Irish, which is impossible after 2020. [36] [37] It relies on specific wording in bi-lateral Irish tax treaties (particularly with Malta and the United Arab Emirates) to re-create the double Irish system and its effective tax rate of <1%.