When.com Web Search

Search results

  1. Results From The WOW.Com Content Network
  2. Double Irish arrangement - Wikipedia

    en.wikipedia.org/wiki/Double_Irish_arrangement

    Ireland's Capital Allowances for Intangible Assets program enables these intangible assets to be turned into tax deductible charges. .. With appropriate structuring, the intergroup acquisition financing for the purchase of these intangible assets, can also be used to further amplify the quantum of tax deductible charges.

  3. Base erosion and profit shifting (OECD project) - Wikipedia

    en.wikipedia.org/wiki/Base_erosion_and_profit...

    Capital allowances for intangible assets is Ireland's long-term replacement for double Irish and single malt. It delivers an effective tax rate of 0-3%. It delivers an effective tax rate of 0-3%. When Apple, the largest user of BEPS tools globally, restructured its controversial double Irish subsidiary in 2015 (as agreed with the EU Commission ...

  4. Capital allowance - Wikipedia

    en.wikipedia.org/wiki/Capital_allowance

    Capital allowances is the practice of allowing tax payers to get tax relief on capital expenditure by allowing it to be deducted against their annual taxable income. . Generally, expenditure qualifying for capital allowances will be incurred on specified capital assets, with the deduction available normally spread over ma

  5. Corporation tax in the Republic of Ireland - Wikipedia

    en.wikipedia.org/wiki/Corporation_tax_in_the...

    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 ] Section 110 SPVs – created in the 1997 TCA with strong anti-avoidance controls, which were eroded in 2003, 2008, 2011 Finance Acts (see Section 110 article).

  6. Base erosion and profit shifting - Wikipedia

    en.wikipedia.org/wiki/Base_erosion_and_profit...

    Even before 2015, Ireland had already publicly replaced the double Irish with two new BEPS tools: the single malt (as used by Microsoft and Allergan), and capital allowances for intangible assets ("CAIA"), also called the "Green Jersey", (as used by Apple in Q1 2015). [53] [54] None of these new BEPS tools have been as yet proscribed by the ...

  7. International Financial Services Centre, Dublin - Wikipedia

    en.wikipedia.org/wiki/International_Financial...

    With the closure of the Double Irish arrangement in 2020, the most important BEPS tool in the IFSC is the Capital Allowances for Intangible Assets (CAIA) BEPS tool. Apple used the CAIA BEPS tool in Q1 2015 to execute the largest BEPS action in history, causing the Leprechaun economics revision of Irish GDP data.

  8. Dutch Sandwich - Wikipedia

    en.wikipedia.org/wiki/Dutch_Sandwich

    [1] [2] The Dutch Sandwich was often used with Irish BEPS tools such as the Double Irish, the Single Malt and the Capital Allowances for Intangible Assets ("CAIA") tools. In 2010, Ireland changed its tax-code to enable Irish BEPS tools to avoid such withholding taxes without needing a Dutch Sandwich.

  9. Capital Allowances Act 2001 - Wikipedia

    en.wikipedia.org/wiki/Capital_Allowances_Act_2001

    An Act to restate, with minor changes, certain enactments relating to capital allowances. Citation: 2001 c. 2: Territorial extent United Kingdom: Dates; Royal assent: 22 March 2001: Commencement: chargeable periods ending on or after 6 April 2001 (income tax) chargeable periods ending on or after 1 April 2001 (corporation tax) Text of statute ...