Search results
Results from the WOW.Com Content Network
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 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]
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 ...
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 ...
These destinations also had advanced IP-based BEPS tools (e.g. the Irish CAIA tool, the Double Irish tool, the UK Patent box tool) that could deliver an "effective tax rate" closer to zero on profits shifted to the destination. [6] [45] The destinations for the 85 US corporate tax inversions since 1983 are as follows: [10]
People sometimes use the terms “tax avoidance” and “tax evasion” interchangeably, but in the eyes of experts and the government there’s one big difference between the two: legality.
EU Commission's outline of Apple's hybrid–double Irish BEPS tax structure in Ireland, ... Tax evasion: Although numbers are difficult to ascertain, ...