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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 ...
It is specifically prohibited under Ireland's own corporation tax code (Section 291A(c) of the Irish Taxes and Consolation Act 1997) to use the CAIA BEPS scheme for reasons that are not "commercial bona fide reasons" and in particular for schemes where the main purpose is "... the avoidance of, or reduction in, liability to tax".
As the BEPS tool with which U.S. multinationals built up untaxed offshore reserves of circa US$1 trillion from 2004 to 2017, [d] [e] [16] [17] the Double Irish is the largest tax avoidance tool in history.
A controversial tax structure dubbed the ‘single malt’ is still being exploited in Ireland, despite Irish government insistence that US tax reforms would effectively put an end to its use.
Furthermore, while tax avoidance is in principle legal, if the IRS in its sole judgment determines that tax avoidance is the 'principal purpose' for an expatriation attempt, 'covered expat' status will be applied to the requester, thereby forcing an expatriation tax on worldwide assets to be paid as a condition of expatriation. [88]
Zucman's analysis highlighted the special case of Ireland and why the Orbis database underestimates Ireland's scale as one of the world's largest corporate tax avoidance, or BEPS, hubs. [80] In 2018, Zucman ( et alia ) showed that many of Ireland's U.S. multinationals don't appear on Orbis (e.g. Facebook), or only have a small fraction of their ...
At the end of 2023, Tesla had a negative effective tax rate, according to its 10-K, and $1.1 billion worth of deferred federal research and development tax credits that it could carry forward ...
When the Section 110 SPV Irish domestic tax avoidance scandals surfaced in late 2016, it was due to Irish financial journalists and Dáil Éireann representatives scrutinising the Irish CRO public accounts of U.S. distressed firms. In November 2016 the Central Bank began to overhaul the L-QIAIF regime.