BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part II of II
THE CLASSIC DOUBLE IRISH WITH A DUTCH SANDWICH (“DIDS”) In Part I of this article, I discussed the mechanism by which some very prominent U.S. multinational companies have been able to reduce global income tax on mobile income, such as royalties on sales of software to, at times, almost nil by routing such income through […]
BEPS -Double Irish/ Dutch Sandwich Hybrid Entity Mismatches – Part I of II
On Monday, October 6, 2015 the OECD (of which the US is a member) delivered its long awaited final BEPS (Base Erosion Profit Shifting) Action Plans. BEPS, which actually has 15 action points, is designed to set up a fair system of global taxation taking into account the global tax issues that have arisen from […]