Exploring Beyond the Double Irish and Green Jersey: Uncovering Diverse Multinational Tax Planning Strategies
November 18, 2020
Apart from the Double Irish with Dutch Sandwich and Green Jersey approach, there are other tax planning strategies that have been used by multinational corporations. Here are a few notable examples:
- Transfer Pricing: Transfer pricing involves determining the prices for goods, services, or intellectual property exchanged between entities within the same multinational group. By setting transfer prices strategically, companies can allocate profits to different jurisdictions, taking advantage of lower tax rates or preferential tax treatments.
- Hybrid Structures: Hybrid structures exploit differences in tax classifications between countries to achieve favorable tax outcomes. These structures involve using entities that are treated differently for tax purposes in different jurisdictions, such as disregarded entities or hybrid instruments. The goal is to create asymmetries that result in reduced tax liabilities.
- Treaty Shopping: Treaty shopping refers to the practice of structuring transactions or establishing entities in a particular jurisdiction primarily to benefit from favorable tax treaties between that jurisdiction and other countries. By leveraging these treaties, companies can access reduced withholding tax rates, capital gains exemptions, or other tax advantages.
- Intellectual Property Holding Companies: Multinational corporations often establish separate entities solely for holding and managing their intellectual property rights. These entities may be located in jurisdictions with favorable tax regimes for intellectual property, enabling companies to centralize and manage their intellectual property portfolios efficiently while minimizing tax obligations.
- Capital Allowance Schemes: Some jurisdictions offer generous capital allowance schemes that incentivize investment in specific industries or types of assets. Companies may structure their operations or investments to take advantage of these schemes, which provide tax relief or accelerated depreciation, ultimately reducing their taxable income.
It's important to note that the effectiveness and legality of these strategies can vary depending on the specific circumstances and the evolving tax regulations in different jurisdictions. Additionally, recent international efforts to combat tax avoidance, such as the BEPS project and the implementation of stricter anti-avoidance measures, have aimed to limit the effectiveness of these strategies and promote a fairer and more transparent global tax system.
