Dutch Sandwich is a base erosion and profit shifting corporate tax tool, used mostly by U.S. multinationals to avoid incurring European Union withholding taxes on untaxed profits as they were being mo
Conduit and sink OFCs
…role of OECD and EU tax havens in tax avoidance from base erosion and profit shifting (BEPS) schemes, like the Double Irish, the Single Malt and the Dutch Sandwich. They regard them as major tax havens in their definitions of tax havens. A report published in Nature in 2017 on the analysis of offshore financial…
Irish Taoiseach Enda Kenny and PwC (Ireland) Managing Partner Feargal O'Rourke, the "architect" of the Double Irish, who lobbied successfully in 2010 for changes to the Irish withholding tax rules, thus removing the need for a Dutch sandwich.
The Dutch Sandwich has helped make the Netherlands the largest global conduit OFC in the world, as it facilitates the movement of EU-sourced profits to non-EU tax-havens