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Double Irish Arrangement
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement. Despite US knowledge of the Double Irish for a decade, it was the European Commission that in October 2014 forced Ireland to close the scheme, starting in January 2015. However, users of existing schemes, such as Apple, Google, Facebook and Pfizer, were given until January 2020 to close them. At the announcement of the closure it was known that multin ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
International Financial Services Centre, Dublin
International is an adjective (also used as a noun) meaning "between nations". International may also refer to: Music Albums * ''International'' (Kevin Michael album), 2011 * ''International'' (New Order album), 2002 * ''International'' (The Three Degrees album), 1975 *''International'', 2018 album by L'Algérino Songs * The Internationale, the left-wing anthem * "International" (Chase & Status song), 2014 * "International", by Adventures in Stereo from ''Monomania'', 2000 * "International", by Brass Construction from ''Renegades'', 1984 * "International", by Thomas Leer from ''The Scale of Ten'', 1985 * "International", by Kevin Michael from ''International'' (Kevin Michael album), 2011 * "International", by McGuinness Flint from ''McGuinness Flint'', 1970 * "International", by Orchestral Manoeuvres in the Dark from '' Dazzle Ships'', 1983 * "International (Serious)", by Estelle from '' All of Me'', 2012 Politics * Political international, any transnational organization of ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Capital Allowances For Intangible Assets (CAIA)
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mostly by United States multinationals since the late 1980s to avoid corporate taxation on non-U.S. profits. It was the largest tax avoidance tool in history and by 2010 was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool; however, 2010 changes to tax laws in Ireland dispensed with this requirement. Despite US knowledge of the Double Irish for a decade, it was the European Commission that in October 2014 forced Ireland to close the scheme, starting in January 2015. However, users of existing schemes, such as Apple, Google, Facebook and Pfizer, were given until January 2020 to close them. At the announcement of the closure it was known that multin ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Revenue Commissioners
The Revenue Commissioners ( ga, Na Coimisinéirí Ioncaim), commonly called Revenue, is the Irish Government agency responsible for customs, excise, taxation and related matters. Though Revenue can trace itself back to predecessors (with the Act of Union 1800 amalgamating its forerunners with HM Customs and Excise in the United Kingdom), the current organisation was created for the independent Irish Free State on 21 February 1923 by the ''Revenue Commissioners Order, 1923'' which established the Revenue Commissioners to carry out the functions that the Commissioners of Inland Revenue and the Commissioners of Customs and Excise had carried out in the Free State prior to independence. The Revenue Commissioners are responsible to the Minister for Finance. Overview Revenue consists of a chairman and two commissioners, all of whom have the status of secretary general as used in Departments of State. The first commissioners, appointed by the then President of the Executive Council ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Treaties
A tax treaty, also called double tax agreement (DTA) or double tax avoidance agreement (DTAA), is an agreement between two countries to avoid or mitigate double taxation. Such treaties may cover a range of taxes including income taxes, inheritance taxes, value added taxes, or other taxes. Besides bilateral treaties, multilateral treaties are also in place. For example, European Union (EU) countries are parties to a multilateral agreement with respect to value added taxes under auspices of the EU, while a joint treaty on mutual administrative assistance of the Council of Europe and the Organisation for Economic Co-operation and Development (OECD) is open to all countries. Tax treaties tend to reduce taxes of one treaty country for residents of the other treaty country to reduce double taxation of the same income. The provisions and goals vary significantly, with very few tax treaties being alike. Most treaties: * define which taxes are covered and who is a resident and eligible ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Zentrum Für Europäische Wirtschaftsforschung
ZEW headquarters in Mannheim The ZEW – Leibniz Centre for European Economic Research (ZEW) in Mannheim is an economic research institute and a member of the Gottfried Wilhelm Leibniz Scientific Community. Under the leadership of Prof. Achim Wambach, PhD, president of the Institute, and Thomas Kohl, managing director, ZEW employs a staff of about 208. ZEW is one of Europe’s leading economic research institutes. ZEW is subdivided into the eight research fields: *Labour Markets and Social Insurance *Economics of Innovation and Industrial Dynamics *Digital Economy *Pensions and Sustainable Financial Markets *Environmental and Climate Economics *Corporate Taxation and Public Finance *Inequality and Public Policy *Market Design and one Research Group: Health Care Markets and Health Policy ZEW’s guiding mission is to study the optimal performance of markets and institutions in Europe. ZEW’s expertise lies particularly in the area of applied microeconometrics and in computable g ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Royalty Payment
A royalty payment is a payment made by one party to another that owns a particular asset, for the right to ongoing use of that asset. Royalties are typically agreed upon as a percentage of gross or net revenues derived from the use of an asset or a fixed price per unit sold of an item of such, but there are also other modes and metrics of compensation.Guidelines for Evaluation of Transfer of Technology Agreements, United Nations, New York, 1979 A royalty interest is the right to collect a stream of future royalty payments. A license agreement defines the terms under which a resource or property are licensed by one party to another, either without restriction or subject to a limitation on term, business or geographic territory, type of product, etc. License agreements can be regulated, particularly where a government is the resource owner, or they can be private contracts that follow a general structure. However, certain types of franchise agreements have comparable provisions. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Intangible Asset
An intangible asset is an asset that lacks physical substance. Examples are patents, copyright, franchises, goodwill, trademarks, and trade names, as well as software. This is in contrast to physical assets (machinery, buildings, etc.) and financial assets (government securities, etc.). An intangible asset is usually very difficult to valuate. They suffer from typical market failures of non- rivalry and non-excludability.Webster, Elisabeth; Jensen, Paul H. (2006). ''Investment in Intangible Capital: An Enterprise Perspective.'' The Economic Record, Vol. 82, No. 256, March, 82-96. Today, a large part of the corporate economy ( NPV) consists of intangible assets. Definition Intangible assets may be one possible contributor to the disparity between "company value as per their accounting records", as well as "company value as per their market capitalization". Considering this argument, it is important to understand what an intangible asset truly is in the eyes of an accountant. A ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Intellectual Property
Intellectual property (IP) is a category of property that includes intangible creations of the human intellect. There are many types of intellectual property, and some countries recognize more than others. The best-known types are patents, copyrights, trademarks, and trade secrets. The modern concept of intellectual property developed in England in the 17th and 18th centuries. The term "intellectual property" began to be used in the 19th century, though it was not until the late 20th century that intellectual property became commonplace in the majority of the world's legal systems."property as a common descriptor of the field probably traces to the foundation of the World Intellectual Property Organization (WIPO) by the United Nations." in Mark A. Lemley''Property, Intellectual Property, and Free Riding'', Texas Law Review, 2005, Vol. 83:1031, page 1033, footnote 4. The main purpose of intellectual property law is to encourage the creation of a wide variety of intellectual go ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Tax Cuts And Jobs Act Of 2017
The Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018, , is a congressional revenue act of the United States originally introduced in Congress as the Tax Cuts and Jobs Act (TCJA), that amended the Internal Revenue Code of 1986. Major elements of the changes include reducing tax rates for businesses and individuals, increasing the standard deduction and family tax credits, eliminating personal exemptions and making it less beneficial to itemize deductions, limiting deductions for state and local income taxes and property taxes, further limiting the mortgage interest deduction, reducing the alternative minimum tax for individuals and eliminating it for corporations, doubling the estate tax exemption, and cancelling the penalty enforcing individual mandate of the Affordable Care Act (ACA). The Act is based on tax reform advocated by congressional Republicans and the Trump administration. The nonpartisan ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Financial Times
The ''Financial Times'' (''FT'') is a British daily newspaper printed in broadsheet and published digitally that focuses on business and economic current affairs. Based in London, England, the paper is owned by a Japanese holding company, Nikkei, with core editorial offices across Britain, the United States and continental Europe. In July 2015, Pearson sold the publication to Nikkei for £844 million ( US$1.32 billion) after owning it since 1957. In 2019, it reported one million paying subscriptions, three-quarters of which were digital subscriptions. The newspaper has a prominent focus on financial journalism and economic analysis over generalist reporting, drawing both criticism and acclaim. The daily sponsors an annual book award and publishes a " Person of the Year" feature. The paper was founded in January 1888 as the ''London Financial Guide'' before rebranding a month later as the ''Financial Times''. It was first circulated around metropolitan London by James Sher ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Irish Section 110 Special Purpose Vehicle (SPV)
An Irish Section 110 special purpose vehicle (SPV) or section 110 company, is an Irish tax resident company, which qualifies under ''Section 110'' of the '' Irish Taxes Consolidation Act 1997'' (TCA) for a special tax regime that enables the SPV to attain "tax neutrality": i.e. the SPV pays no Irish taxes, VAT, or duties. Section 110 was created in 1997 to help International Financial Services Centre (IFSC) legal and accounting firms compete for the administration of global securitisation deals, and by 2017 was the largest structured finance vehicle in EU securitisation. Section 110 SPVs have made the IFSC the third largest global Shadow Banking OFC. While they pay no Irish tax, they contribute €100 million annually to the Irish economy in fees paid to IFSC legal and accounting firms. In June 2016, it was discovered that US distressed debt funds used Section 110 SPVs, structured by IFSC service firms, to avoid Irish taxes on €80 billion of Irish domestic investments. ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Qualifying Investor Alternative Investment Fund (QIAIF)
Qualifying Investor Alternative Investment Fund or QIAIF is a Central Bank of Ireland regulatory classification established in 2013 for Ireland's five tax-free legal structures for holding assets. The Irish Collective Asset-management Vehicle or ICAV is the most popular of the five Irish QIAIF structures, it is the main tax-free structure for foreign investors holding Irish assets. In 2018, the Central Bank of Ireland expanded the Loan Originating QIAIF or L–QIAIF regime which enables the five tax-free structures to be used for closed-end debt instruments. The L–QIAIF is Ireland's main debt–based BEPS tool as it overcomes the lack of confidentiality and tax secrecy of the Section 110 SPV. It is asserted that many assets in QIAIFs and LQIAIFs are Irish assets being shielded from Irish taxation. Irish QIAIFs and LQIAIFs can be integrated with Irish corporate base erosion and profit shifting ("BEPS") tax tools to create confidential routes out of the Irish tax system ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
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