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Dutch Sandwich
Videos
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
Irish Taoiseach Enda Kenny and PwC (Ireland) Managing Partner Feargal O'Rourke, the "architect" of the Double Irish, who lobbied successfully in 2010
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 t
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
Double Irish arrangement
Videos
The Double Irish arrangement was a base erosion and profit shifting corporate tax avoidance tool used mainly by United States multinationals between the late 1980s and late 2010s to avoid corporate ta
Dutch Sandwich
…tax havens, such as Ireland and Luxembourg, by the use of other BEPS tools. 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…
International Financial Services Centre (IFSC), centre of US multinational tax planning in Ireland
International Financial Services Centre (IFSC), centre of US multinational tax planning in Ireland
Former Finance Minister Michael Noonan closed the Double Irish BEPS tool to new entrants in October 2014 (existing schemes to close by 2020), but expa
Former Finance Minister Michael Noonan closed the Double Irish BEPS tool to new entrants in October 2014 (existing schemes to close by 2020), but expanded the CAIA BEPS tool as a replacement in 2011–2016, and infamously told an Irish MEP who alerted him to the Single Malt BEPS tool, to "put on the green jersey".
The EU Commission's diagram of Apple's "Double Irish" BEPS tool
The EU Commission's diagram of Apple's "Double Irish" BEPS tool
Margrethe Vestager, announcing Apple's €13 billion fine for Irish taxes avoided from 2004 to 2014 via an illegal "Double Irish" BEPS scheme
Margrethe Vestager, announcing Apple's €13 billion fine for Irish taxes avoided from 2004 to 2014 via an illegal "Double Irish" BEPS scheme