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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 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 ...
Apple's IP–based BEPS tools, which was mainly the Double Irish BEPS scheme (2013 Senate Report) ASI's 2014 structure was an adaptation of a Double Irish scheme, an Irish IP–based BEPS tool used by many US multinationals. Apple did not follow the traditional Double Irish structure of using two separate Irish companies.
Sinn Fein brought a private members bill to Dail Eireann on Tuesday evening ‘in response to cries from Gaza’.
Tax on offshore reserves. Tax academics have shown that the dominance of US corporations in using tax havens was driven by strategies to shield non-US income from US taxation. [51] BEPS tools such as the "Double Irish", [45] enabled US corporations to build up untaxed offshore cash reserves estimated at US$1–2 trillion in 2017. [47]
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 ...