This is a famous tax avoidance strategy adopted by renowned multinationals like Apple, Google etc. This unique arrangement will leave you amazed and it is also very informative. Please read the detailed report to know more.
This document provides an overview of DHL Express's air cargo market in Ludhiana, India. It discusses the origins and components of logistics, introduces DHL and its vision/mission. It describes DHL Express India's services like time-definite and day-definite international delivery. Financial ratios and trends for Deutsche Post DHL are analyzed. The document also outlines the objectives and methodology of a study on the air express market in Ludhiana, presenting results on customer awareness, preferences, and satisfaction with DHL. It recommends DHL work on pricing strategy and promotions in the region to better capitalize on the air cargo expenditure potential in Ludhiana.
5P, 7R, Entry Strategy, Packaging StartegySnehal Deo
International Logistics at IKEA
IKEA is a Swedish multinational group founded in 1943 that designs and sells ready-to-assemble furniture and home accessories. It has 31 distribution centers in 16 countries and sources from over 1350 suppliers in 50 countries. IKEA uses efficient production and transportation methods like flat packing and container vessels to distribute goods from suppliers around the world to its 423 stores located within 600km of distribution centers, using various modes of transportation. Its logistics strategy focuses on getting the right products to the right customers at the right time, place, condition, quantity and cost.
This document discusses predictions for the diaper industry over the next 25 years. It predicts that the global baby diaper market will nearly double in size by 2025 as diaper usage increases in developing countries. The adult diaper market is also expected to grow substantially, increasing over 3 times by 2025 due to demographic trends. Key growth areas are expected to be China, India, and Brazil as incomes rise in those countries. The document also discusses factors like cultural barriers that may impact market penetration in various regions.
Balance Of Payment - International MarketingSachin7443
The document discusses the balance of payments of a country. It defines balance of payments as a systematic record of all economic transactions between a country and the rest of the world. It is the difference between receipts from and payments to foreign countries. The balance of payments has a current account and a capital account. The current account includes imports/exports of goods and services and unilateral transfers. The capital account includes foreign investment, loans, and other financial flows. An overall balance of payments is calculated as the current account balance plus the capital account balance plus changes in official reserves. A deficit in the current account is referred to as a current account deficit. Causes and measures to correct a balance of payments deficit are also discussed.
This document provides an overview of the logistics industry and Porter's Five Forces analysis. It discusses key domestic and international players like DHL, TNT, AFL, Exel, Kuehne & Nagel, and Schenker. Opportunities for growth in India include air cargo and the Delhi-Mumbai corridor project. Challenges are high costs due to delays and poor infrastructure. The future of e-commerce and initiatives like 'Make in India' are expected to drive growth in the logistics sector.
E-business represents the use of electronic technology, especially the internet, for business purposes. It allows companies to connect with suppliers, distributors, and business partners through tools like data warehousing and networks. E-business also allows companies to participate in larger online business communities. The document then defines several common e-business terms and discusses infrastructure requirements, costs, and marketing strategies for e-business.
The document outlines the key steps in the export procedure in China:
1. Companies must register with authorities like MOFCOM to obtain export rights.
2. Exporters also need to register for customs, tax, and foreign exchange purposes with agencies such as the General Administration of Customs and SAFE.
3. An export contract detailing items like price, payment terms, and insurance must be signed.
4. Arrangements are made for shipping, which may involve freight forwarders and bills of lading.
5. Licenses may be required for certain controlled export goods based on the export commodity catalogue.
6. Mandatory inspection is needed for some products based on another
The document provides an overview of mergers and acquisitions. It defines mergers and acquisitions, outlines the key differences between them, and describes the typical procedures involved. Some of the main advantages and motives for mergers and acquisitions discussed are achieving economies of scale, increasing market share and revenue, enabling cross-selling opportunities between companies, realizing synergies from specialization, and seeking tax benefits. The document also provides examples of major mergers and acquisitions deals.
This document provides an overview of DHL Express's air cargo market in Ludhiana, India. It discusses the origins and components of logistics, introduces DHL and its vision/mission. It describes DHL Express India's services like time-definite and day-definite international delivery. Financial ratios and trends for Deutsche Post DHL are analyzed. The document also outlines the objectives and methodology of a study on the air express market in Ludhiana, presenting results on customer awareness, preferences, and satisfaction with DHL. It recommends DHL work on pricing strategy and promotions in the region to better capitalize on the air cargo expenditure potential in Ludhiana.
5P, 7R, Entry Strategy, Packaging StartegySnehal Deo
International Logistics at IKEA
IKEA is a Swedish multinational group founded in 1943 that designs and sells ready-to-assemble furniture and home accessories. It has 31 distribution centers in 16 countries and sources from over 1350 suppliers in 50 countries. IKEA uses efficient production and transportation methods like flat packing and container vessels to distribute goods from suppliers around the world to its 423 stores located within 600km of distribution centers, using various modes of transportation. Its logistics strategy focuses on getting the right products to the right customers at the right time, place, condition, quantity and cost.
This document discusses predictions for the diaper industry over the next 25 years. It predicts that the global baby diaper market will nearly double in size by 2025 as diaper usage increases in developing countries. The adult diaper market is also expected to grow substantially, increasing over 3 times by 2025 due to demographic trends. Key growth areas are expected to be China, India, and Brazil as incomes rise in those countries. The document also discusses factors like cultural barriers that may impact market penetration in various regions.
Balance Of Payment - International MarketingSachin7443
The document discusses the balance of payments of a country. It defines balance of payments as a systematic record of all economic transactions between a country and the rest of the world. It is the difference between receipts from and payments to foreign countries. The balance of payments has a current account and a capital account. The current account includes imports/exports of goods and services and unilateral transfers. The capital account includes foreign investment, loans, and other financial flows. An overall balance of payments is calculated as the current account balance plus the capital account balance plus changes in official reserves. A deficit in the current account is referred to as a current account deficit. Causes and measures to correct a balance of payments deficit are also discussed.
This document provides an overview of the logistics industry and Porter's Five Forces analysis. It discusses key domestic and international players like DHL, TNT, AFL, Exel, Kuehne & Nagel, and Schenker. Opportunities for growth in India include air cargo and the Delhi-Mumbai corridor project. Challenges are high costs due to delays and poor infrastructure. The future of e-commerce and initiatives like 'Make in India' are expected to drive growth in the logistics sector.
E-business represents the use of electronic technology, especially the internet, for business purposes. It allows companies to connect with suppliers, distributors, and business partners through tools like data warehousing and networks. E-business also allows companies to participate in larger online business communities. The document then defines several common e-business terms and discusses infrastructure requirements, costs, and marketing strategies for e-business.
The document outlines the key steps in the export procedure in China:
1. Companies must register with authorities like MOFCOM to obtain export rights.
2. Exporters also need to register for customs, tax, and foreign exchange purposes with agencies such as the General Administration of Customs and SAFE.
3. An export contract detailing items like price, payment terms, and insurance must be signed.
4. Arrangements are made for shipping, which may involve freight forwarders and bills of lading.
5. Licenses may be required for certain controlled export goods based on the export commodity catalogue.
6. Mandatory inspection is needed for some products based on another
The document provides an overview of mergers and acquisitions. It defines mergers and acquisitions, outlines the key differences between them, and describes the typical procedures involved. Some of the main advantages and motives for mergers and acquisitions discussed are achieving economies of scale, increasing market share and revenue, enabling cross-selling opportunities between companies, realizing synergies from specialization, and seeking tax benefits. The document also provides examples of major mergers and acquisitions deals.
Consumer Science and Product Development at Netflix - OSCON 2012Matt Marenghi
1) Netflix uses consumer science and A/B testing to improve the user experience and increase customer satisfaction and retention.
2) Scientists form hypotheses about potential product improvements and then test different variations through controlled experiments with real customers.
3) The results of A/B tests help Netflix determine which changes to roll out more broadly or iterate further based on metrics like hours watched and retention rates.
The document discusses electronic business (e-business) and electronic commerce (e-commerce), defining them and differentiating the two. It then lists three successful e-commerce companies (Amazon, Dell, Apple) and three failed ones (MVP.com, Thought Inc., Channel A), providing brief explanations for each. Finally, it discusses factors driving and inhibiting e-commerce growth in India, and provides statistics on e-commerce usage and growth in the country from 2006-2011.
DHL uses data science and AI throughout its operations to improve efficiency, customer experience, and decision making. It analyzes data such as origin/destination, size/weight of shipments, vehicle locations, and customer interactions to predict delays, demand, and risks. Machine learning helps optimize routing, staffing, and warehouse management. AI tools identify damaged packages and monitor suppliers for risks. This informs decisions that lead to reliable delivery, increased profits and customer satisfaction.
This document provides information about DHL Supply Chain and its services. It discusses that DHL Supply Chain offers customized logistics solutions across the entire supply chain. It then describes the various services offered by DHL Supply Chain, including DHL Express, DHL Global Forwarding, DHL Solutions, DHL Global Mail, cold chain logistics, warehousing and distribution, customer resource area, and challenges and advantages of DHL Supply Chain.
Carrefour and Hypermart both employ everyday low pricing strategies. Carrefour offers weekly promos while Hypermart focuses on combo deals. Both companies place products based on customer shopping habits and have online shopping and delivery options. They each offer loyalty programs through membership cards and vouchers. Carrefour has 16 product catalogs while Hypermart has 12, and both companies sell original food products under their private labels.
This document discusses factors to consider in making location decisions. It provides discussion questions about specific companies' location strategies, such as FedEx choosing Memphis for its central location. It also lists numerous qualitative and quantitative factors that can influence location decisions for companies operating domestically or internationally. These factors include labor costs, transportation costs, resources, market access, incentives, and business environment considerations like regulations and cultural issues. The document presents examples and models for analyzing location decisions in a structured way.
Summer Internship project On Study of 3PLKapil Mittal
This project was basically done to find out the errors that are encountered by a logistics company and how can they overcome those error by using the required technology
International Business Meaning
• International business consists of trades and transactions at a global level. These include the trade of goods, services, technology, capital and/or knowledge."International business" is also defined as the study of the internationalization process of multinational enterprises.
logistics industry and pestle and marketing mix swot analyis of itPratik Louhar
The document provides an overview of the logistics industry. It discusses key concepts in logistics like order processing, inventory management, transportation, and warehousing. It then performs a PESTLE analysis to examine the political, economic, social, technological, legal and environmental factors affecting the industry. Three major companies are profiled - FedEx, GATI and Allcargo Logistics. Their business models and financials are analyzed. Finally, SWOT analyses are presented for each company to identify their strengths, weaknesses, opportunities and threats.
Inventory system and supply chain of IKEA multi national furniture industryHaider Sabir
IKEA has an inventory management system designed to support its vision of providing affordable home furnishings. It uses sustainable materials and negotiates long-term contracts with suppliers to keep costs low. IKEA stores products in flat packages and encourages self-assembly and retrieval to minimize handling costs. Inventory is managed through automated high-flow warehouses and manual low-flow warehouses. Logistics are outsourced to experienced partners to efficiently deliver products to IKEA's 355 stores worldwide.
The document provides an overview of the logistics industry in India. It discusses key concepts in logistics like inventory management, transportation methods, and activities involved. It also shares statistics on India's spending on logistics. The major companies discussed are FedEx, DHL and DTDC which are compared on their services, prices, promotion strategies, processes and financial performance. SWOT analyses are also presented for each company. The document utilizes diagrams and tables to analyze the companies' current ratios, asset turnover ratios, debt-equity ratios, net profit margins and other financial metrics. It concludes with references used for the report.
The Bangladesh Export Processing Zone Authority (BEPZA) (Bengali: বাংলাদেশ রপ্তানি প্রক্রিয়াকরণ অঞ্চল কর্তৃপক্ষ) is an agency of the Government of Bangladesh and is administered out of the Prime Minister's Office. Its objective is to manage the various export processing zones in Bangladesh. BEPZA currently oversees the operations of eight export processing zones (EPZ). A ninth zone is scheduled to open in the future. Recently government has announced that in 15 years 100 new EPZ and SEZ will be established.
DHL was founded in 1969 and is headquartered in Germany. It operates in over 220 countries with over 500,000 employees. The document discusses DHL's history and expansion internationally since the 1970s. It also describes DHL's operations and facilities in Pakistan, focusing on an airside facility opened in 2008. The document then covers DHL's mission, vision, goals, organizational structure, financial performance, and efforts to promote diversity, ethics, employee satisfaction, and stress management.
E-commerce and its impact on international tradeHIMANI SONI
E-commerce has become an important part of international trade by allowing businesses and consumers to conduct transactions across borders through online platforms. Global production networks in industries like automobiles and electronics rely heavily on e-commerce and IT for coordination. As countries integrate further into these global networks and face increasing competition, there is more pressure to adopt e-commerce to reduce costs and expand markets. While e-commerce provides benefits like access to global markets and efficiency, it also presents challenges such as delivery costs, cultural differences, and building customer trust in cross-border transactions.
Service Blueprint - Supply Chain Logistics DHLTushar G
Service design is a complex task that can benefit from a more flow charting known as service blueprinting.
Jane Kingman - Brundage (1989) developed an effective approach for blueprinting
A STUDY ON CUSTOMER’S SATISFACTION MARKS CARGO PRIVATE LIMITED - 2Yogesh Santhan
This study entitled “A STUDY ON CUSTOMER’S SATISFACTION AT MARKS CARGO PRIVATE LIMITED, PONDICHERRY” is based on the services provided such as experience and opinion of the customers. By using their feedback it enables to determine the effectiveness.
This project explains ways in which customers feedback to implement the changes in the process can be used in long run. The primary data was collected from 54 customers from various industry sectors. The collected data were analyzed and it’s found that majority of them were aware and satisfied with the current services and have participated also. They suggest that certain aspects of the services and its process could be redefined and they should be updated based on the feedback of the customers towards it.
The study not only projects the current status of organization service process but also serves as a stepping stone to remedial measure for MARKS CARGO PRIVATE LIMITED.
This document provides an overview of key export and import documents. It discusses commercial documents needed for export such as export sales contracts, proforma invoices, certificates of origin, bills of lading, and airway bills. It also discusses regulatory documents required for export like shipping bills and export declaration forms. For imports, it outlines important documents like invoices, packing lists, bills of lading, import licenses, and bills of entry that must be submitted to customs. Overall, the document emphasizes the importance of documentation in international trade for legal and commercial purposes.
Castlight Health provides a cloud-based software platform that helps companies and employees make more informed healthcare decisions to reduce costs and improve quality of care. The platform provides personalized cost and quality information to help employees choose high-value care options. Castlight has over 100 clients ranging from medium to large businesses that have seen a reduction in healthcare spending through the use of their platform.
This is a famous tax avoidance strategy adopted by renowned multinationals like Apple, Google etc. This unique arrangement will leave you amazed and it is also very informative. It tells us about the loop holes in the legal systems which are sometimes utilised by business entities to increase profits.
Ireland offers an attractive business location for multinational companies, with a 12.5% corporate tax rate, double taxation treaties with 72 countries, and generous R&D and intellectual property tax incentives. Setting up a new company or branch is quick and straightforward, with no minimum capital requirements or need for Irish shareholders or officers. The tax system provides an effective zero tax rate on foreign dividends and income tax relief for foreign employees.
Consumer Science and Product Development at Netflix - OSCON 2012Matt Marenghi
1) Netflix uses consumer science and A/B testing to improve the user experience and increase customer satisfaction and retention.
2) Scientists form hypotheses about potential product improvements and then test different variations through controlled experiments with real customers.
3) The results of A/B tests help Netflix determine which changes to roll out more broadly or iterate further based on metrics like hours watched and retention rates.
The document discusses electronic business (e-business) and electronic commerce (e-commerce), defining them and differentiating the two. It then lists three successful e-commerce companies (Amazon, Dell, Apple) and three failed ones (MVP.com, Thought Inc., Channel A), providing brief explanations for each. Finally, it discusses factors driving and inhibiting e-commerce growth in India, and provides statistics on e-commerce usage and growth in the country from 2006-2011.
DHL uses data science and AI throughout its operations to improve efficiency, customer experience, and decision making. It analyzes data such as origin/destination, size/weight of shipments, vehicle locations, and customer interactions to predict delays, demand, and risks. Machine learning helps optimize routing, staffing, and warehouse management. AI tools identify damaged packages and monitor suppliers for risks. This informs decisions that lead to reliable delivery, increased profits and customer satisfaction.
This document provides information about DHL Supply Chain and its services. It discusses that DHL Supply Chain offers customized logistics solutions across the entire supply chain. It then describes the various services offered by DHL Supply Chain, including DHL Express, DHL Global Forwarding, DHL Solutions, DHL Global Mail, cold chain logistics, warehousing and distribution, customer resource area, and challenges and advantages of DHL Supply Chain.
Carrefour and Hypermart both employ everyday low pricing strategies. Carrefour offers weekly promos while Hypermart focuses on combo deals. Both companies place products based on customer shopping habits and have online shopping and delivery options. They each offer loyalty programs through membership cards and vouchers. Carrefour has 16 product catalogs while Hypermart has 12, and both companies sell original food products under their private labels.
This document discusses factors to consider in making location decisions. It provides discussion questions about specific companies' location strategies, such as FedEx choosing Memphis for its central location. It also lists numerous qualitative and quantitative factors that can influence location decisions for companies operating domestically or internationally. These factors include labor costs, transportation costs, resources, market access, incentives, and business environment considerations like regulations and cultural issues. The document presents examples and models for analyzing location decisions in a structured way.
Summer Internship project On Study of 3PLKapil Mittal
This project was basically done to find out the errors that are encountered by a logistics company and how can they overcome those error by using the required technology
International Business Meaning
• International business consists of trades and transactions at a global level. These include the trade of goods, services, technology, capital and/or knowledge."International business" is also defined as the study of the internationalization process of multinational enterprises.
logistics industry and pestle and marketing mix swot analyis of itPratik Louhar
The document provides an overview of the logistics industry. It discusses key concepts in logistics like order processing, inventory management, transportation, and warehousing. It then performs a PESTLE analysis to examine the political, economic, social, technological, legal and environmental factors affecting the industry. Three major companies are profiled - FedEx, GATI and Allcargo Logistics. Their business models and financials are analyzed. Finally, SWOT analyses are presented for each company to identify their strengths, weaknesses, opportunities and threats.
Inventory system and supply chain of IKEA multi national furniture industryHaider Sabir
IKEA has an inventory management system designed to support its vision of providing affordable home furnishings. It uses sustainable materials and negotiates long-term contracts with suppliers to keep costs low. IKEA stores products in flat packages and encourages self-assembly and retrieval to minimize handling costs. Inventory is managed through automated high-flow warehouses and manual low-flow warehouses. Logistics are outsourced to experienced partners to efficiently deliver products to IKEA's 355 stores worldwide.
The document provides an overview of the logistics industry in India. It discusses key concepts in logistics like inventory management, transportation methods, and activities involved. It also shares statistics on India's spending on logistics. The major companies discussed are FedEx, DHL and DTDC which are compared on their services, prices, promotion strategies, processes and financial performance. SWOT analyses are also presented for each company. The document utilizes diagrams and tables to analyze the companies' current ratios, asset turnover ratios, debt-equity ratios, net profit margins and other financial metrics. It concludes with references used for the report.
The Bangladesh Export Processing Zone Authority (BEPZA) (Bengali: বাংলাদেশ রপ্তানি প্রক্রিয়াকরণ অঞ্চল কর্তৃপক্ষ) is an agency of the Government of Bangladesh and is administered out of the Prime Minister's Office. Its objective is to manage the various export processing zones in Bangladesh. BEPZA currently oversees the operations of eight export processing zones (EPZ). A ninth zone is scheduled to open in the future. Recently government has announced that in 15 years 100 new EPZ and SEZ will be established.
DHL was founded in 1969 and is headquartered in Germany. It operates in over 220 countries with over 500,000 employees. The document discusses DHL's history and expansion internationally since the 1970s. It also describes DHL's operations and facilities in Pakistan, focusing on an airside facility opened in 2008. The document then covers DHL's mission, vision, goals, organizational structure, financial performance, and efforts to promote diversity, ethics, employee satisfaction, and stress management.
E-commerce and its impact on international tradeHIMANI SONI
E-commerce has become an important part of international trade by allowing businesses and consumers to conduct transactions across borders through online platforms. Global production networks in industries like automobiles and electronics rely heavily on e-commerce and IT for coordination. As countries integrate further into these global networks and face increasing competition, there is more pressure to adopt e-commerce to reduce costs and expand markets. While e-commerce provides benefits like access to global markets and efficiency, it also presents challenges such as delivery costs, cultural differences, and building customer trust in cross-border transactions.
Service Blueprint - Supply Chain Logistics DHLTushar G
Service design is a complex task that can benefit from a more flow charting known as service blueprinting.
Jane Kingman - Brundage (1989) developed an effective approach for blueprinting
A STUDY ON CUSTOMER’S SATISFACTION MARKS CARGO PRIVATE LIMITED - 2Yogesh Santhan
This study entitled “A STUDY ON CUSTOMER’S SATISFACTION AT MARKS CARGO PRIVATE LIMITED, PONDICHERRY” is based on the services provided such as experience and opinion of the customers. By using their feedback it enables to determine the effectiveness.
This project explains ways in which customers feedback to implement the changes in the process can be used in long run. The primary data was collected from 54 customers from various industry sectors. The collected data were analyzed and it’s found that majority of them were aware and satisfied with the current services and have participated also. They suggest that certain aspects of the services and its process could be redefined and they should be updated based on the feedback of the customers towards it.
The study not only projects the current status of organization service process but also serves as a stepping stone to remedial measure for MARKS CARGO PRIVATE LIMITED.
This document provides an overview of key export and import documents. It discusses commercial documents needed for export such as export sales contracts, proforma invoices, certificates of origin, bills of lading, and airway bills. It also discusses regulatory documents required for export like shipping bills and export declaration forms. For imports, it outlines important documents like invoices, packing lists, bills of lading, import licenses, and bills of entry that must be submitted to customs. Overall, the document emphasizes the importance of documentation in international trade for legal and commercial purposes.
Castlight Health provides a cloud-based software platform that helps companies and employees make more informed healthcare decisions to reduce costs and improve quality of care. The platform provides personalized cost and quality information to help employees choose high-value care options. Castlight has over 100 clients ranging from medium to large businesses that have seen a reduction in healthcare spending through the use of their platform.
This is a famous tax avoidance strategy adopted by renowned multinationals like Apple, Google etc. This unique arrangement will leave you amazed and it is also very informative. It tells us about the loop holes in the legal systems which are sometimes utilised by business entities to increase profits.
Ireland offers an attractive business location for multinational companies, with a 12.5% corporate tax rate, double taxation treaties with 72 countries, and generous R&D and intellectual property tax incentives. Setting up a new company or branch is quick and straightforward, with no minimum capital requirements or need for Irish shareholders or officers. The tax system provides an effective zero tax rate on foreign dividends and income tax relief for foreign employees.
The document summarizes a presentation on international tax given at a Seattle conference. It discusses key aspects of the US and Irish tax systems, including:
- The US worldwide tax system and how it differs from territorial systems
- How the US foreign tax credit works to prevent double taxation
- How US companies can defer domestic taxes on foreign subsidiary earnings until repatriation
- Transfer pricing policies and challenges in allocating profits between jurisdictions
- Ireland's attractive tax features for multinational corporations like its 12.5% corporate tax rate and participation exemption regime.
International Tax Planning as Viewed through the Eyes of BEPSLewis Rice
Lewis Rice attorney Timothy G. Stewart co-presented to the St. Louis International Tax Group on the OECD's efforts to address Base Erosion and Profit Shifting.
Idataxbrochure2013final 130508035913-phpapp01Agatha C Melvin
This document provides an overview of corporate taxation in Ireland. Some key points include:
- Ireland has a 12.5% corporate tax rate on trading income, one of the lowest statutory rates globally.
- Tax relief is available for interest, capital allowances, losses that can be carried forward, and group relief between qualifying companies.
- The tax regime also provides incentives like a 25% R&D tax credit and tax benefits for intellectual property and holding companies.
- Ireland aims to maintain a stable and transparent tax system that complies with international standards.
This document provides information about Crowleys DFK, an Irish accounting firm that is a member of DFK International. It summarizes Crowleys DFK's services, experience, and case studies working with foreign direct investment clients. Some key points include that Crowleys DFK assists international clients with tax planning, corporate structuring when investing in Ireland, and ongoing compliance and outsourcing services once set up. It highlights Ireland's competitive tax regime and skilled workforce as benefits for foreign investment. Case studies show the firm's work with clients from sectors like software, data centers, manufacturing, and media.
Irish Holding Company Setup and TaxationBridgeWest.eu
The ease of creation and taxation are the main advantages of Irish holding companies. Discover more information about this business form here:https://irelandcompanyformation.com/taxation-of-holding-companies-in-ireland/.
Corporate inversions occur when a corporation reincorporates in another country to reduce its tax burden from income earned abroad. The U.S. has the highest corporate tax rate among OECD countries, incentivizing inversions. Legislation in 1984 and 2004 attempted to curb inversions, but many still occur to take advantage of lower foreign tax rates. The Stop Corporate Inversions Act of 2014 aimed to further limit inversions by increasing the foreign ownership threshold, but was opposed by business groups and Republicans concerned about lost jobs and competitiveness. Views on inversions differ, with some seeing them as unpatriotic and others as a natural response to tax incentives.
This document summarizes the key benefits of investing in Ireland for businesses. It notes that Ireland has the 6th best business environment globally and the 1st in the EU. Ireland also has a young, skilled workforce and is home to over 1,200 multinational companies due to its strategic location, low 12.5% corporate tax rate, and incentives like a 25% R&D tax credit. The document highlights several major companies that have expanded their operations in Ireland in recent years and outlines the country's visa and work permit processes as well as incentives for hiring and living in Ireland. It concludes by introducing Grant Thornton, an accounting and advisory firm that can help businesses establish and grow their operations in Ireland.
An intellectual property holding company (IPHC) is established to hold all intellectual property (IP) of a company group. IPHCs allow businesses to reduce state taxes while separating IP assets from other corporate liabilities. Companies set up IPHCs for tax planning purposes, to protect IP assets in insolvency cases, and to centrally manage IP for administrative efficiencies. The greatest benefit of an IPHC is the reduction in total tax obligations through favorable tax regimes that exempt some or all IPHC income from taxation.
While federal income tax aims to be progressive by taxing higher incomes at higher rates, the overall tax system is not truly progressive due to various factors. Federal income tax accounts for about two-thirds of taxes paid, but state taxes are often regressive, taking a larger share from low and middle incomes. Some states have no income tax, instead relying on other taxes like sales tax. The interaction of federal, state, and local taxes determines the true burden faced by income groups.
DMIEXPO - Arosal - Where To Hold Your IP: The A To Z Guide For Digital MarketersMorning Dough
Arosal will walk you through the challenges and pitfalls which characterize the global tax scene post-BEPS, specifically as regards IP Boxes and the so-called ‘Nexus’ approach. We shall walk you through the process of registering and protecting your IP, whilst designing a robust international structure which will stand up to any BEPS-related challenge.
Furthermore, Arosal will outline the services which you will require, and the process through which these will be obtained regarding the implementation of your structure, whilst focusing on the tax optimization of the group’s entire structure as concerns all types of taxes. Finally, we shall discuss the administration of your international structure, and comment on the way forward in the global market place.
This document provides an overview of R&D tax credits in the UK. Some key points:
- R&D tax credits incentivize companies to invest in innovative technology by providing tax relief of up to 32% of qualifying R&D costs.
- Both profitable and unprofitable companies can claim tax credits, either as a reduction in taxes owed or as a cash refund.
- Qualifying costs include direct labor, external staff, subcontracted R&D work, and consumables used in R&D projects.
- To qualify for credits, projects must involve technical uncertainty that a competent professional could not easily resolve.
Ireland offers several benefits for businesses moving or establishing operations, including continued access to the EU market after Brexit, a highly educated workforce, competitive corporate tax rates and incentives for research and development. The document discusses how the company SmartMBS can help businesses with all legal, tax, accounting and operational needs to set up their business in Ireland.
The Presentation was focussed on the use of low or nil tax jurisdictions typically known to be as Tax Havens by Big Corporate to meticulously route their revenue and using instruments like Double Dutch Sandwich to evade taxes.
- Double taxation occurs when the same income is taxed twice, such as income being taxed in both the country where it was earned and the country of the taxpayer's residence.
- Double Taxation Avoidance Agreements (DTAAs) are designed to protect taxpayers from double taxation and encourage international trade and investment. However, these agreements can also be abused through practices like treaty shopping.
- Treaty shopping occurs when a resident of a third country seeks to obtain benefits from a DTAA between two other countries by establishing a company or entity in one of those countries. This allows the taxpayer to access favorable tax rates.
Similar to Double irish with Dutch sandwich arrangement (20)
Brian Fitzsimmons on the Business Strategy and Content Flywheel of Barstool S...Neil Horowitz
On episode 272 of the Digital and Social Media Sports Podcast, Neil chatted with Brian Fitzsimmons, Director of Licensing and Business Development for Barstool Sports.
What follows is a collection of snippets from the podcast. To hear the full interview and more, check out the podcast on all podcast platforms and at www.dsmsports.net
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IMPACT Silver is a pure silver zinc producer with over $260 million in revenue since 2008 and a large 100% owned 210km Mexico land package - 2024 catalysts includes new 14% grade zinc Plomosas mine and 20,000m of fully funded exploration drilling.
Best practices for project execution and deliveryCLIVE MINCHIN
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Double irish with Dutch sandwich arrangement
1. Research paper
Report on the topic
DOUBLE IRISH ARRANGEMENT WITH DUTCH SANDWICH
Submitted by
Samyak Chaudhary
2. INTRODUCTION
It is always considered to increase your profit margin by the method of saving taxes is quite risky yet
essential, even in todays time where technology has enables transactions to be quicker and intangible
objects to be easily transferred. When companies are earning millions as profits, then they seek these
options.
Double Irish with Dutch sandwich is just one of a class of similar international tax avoidance schemes.
The prime focus is to analyze the Double Irish and Dutch Sandwich tax structures used by large
multinational enterprises and any other inferences that can be made from these. These structures
enable companies to shift significant profits to offshore tax havens through the use of wholly owned
subsidiaries in Ireland and the Netherlands. This report is just an attempt to understand the
arrangement. Hence, we have tried to explain this in the simplest way as we can. As far as our own
interpretation is concerned, the priority of this report is to mention some alternatives available to
undertake these strategies, the ways they are being monitored and analyzing the ethical nature of them,
rather than coming out with groundbreaking innovative ideas to undertake them. The strategies
explained ignore many practical problems that companies actually face who are involved in these
arrangements and the later part of the report deals with our own interpretations.
3. EXPLAINATION
As per the actual process is concerned, the proper name assigned to this strategy is “Double Irish with
Dutch sandwich”. The question is how does a Dutch company get sandwiched between the 2 Irish ones?
The fact to be kept in mind that large corporations follow this so the dealing are in billions. Now, these
companies, first through one Irish company, then to a Dutch company and finally to a second Irish
company headquartered in a tax haven, shift their profits. And large companies have indeed reduced
their taxable income by dramatic figures.
Nations can be really stubborn and irrational in terms of determining national tax codes. That is why
smarter people take advantage of this. Companies form subsidiaries in different land, and make
transactions between them, where they might pay in terms of the profit margin. It can be easily
understood from here on that income once shifted to a low tax zone will still be white, so technically,
legal.
These techniques are most prominently used by tech companies because these firms can easily shift
large portions of profits to other countries by assigning intellectual property rights to subsidiaries
abroad. Hence, we found all the examples to be tech companies indeed! (Google, Amazon, Apple etc.)
Why intellectual property? Because they are intangible so no real commodity transferred hence no costs
associated, therefore only payments need to be made. Now, paying the subsidiaries to enable them to
be licensed
PRIME FACTORS
The basis of this arrangement is the Irish law. It has a feature that companies based outside Ireland can
be registered as an Irish company. This can be a reason of why Ireland is chosen as a destination. Other
factors include a low corporate tax rate, favorable tax treaties that limit the tax on transactions
between subsidiaries, and a well-educated and English speaking workforce.1
1. John Sokatch “Transfer-Pricing with Sofware Allows for Effective Circumvention of Subpart F Income:
Google’s ‘Sandwich’ Costs Taxpayers Millions” (2011) 45 Int’l Law 725 at 732.
4. PROCEDURE
The process goes like this that assuming A is a major tech company. It will set up a subsidiary in Ireland
named B, which will further go on to set another subsidiary named C also in Ireland. At this position,
company incorporated in Ireland will be treated as resident in Ireland for tax purposes.1
For a company to be an exception to this, it has to be a relevant company, that means, it is
ultimately controlled by persons resident in the EU or in a country with which Ireland has concluded a
double taxation treaty.2
US has a double-taxation treaty with Ireland3
, hence subsidiary B can be
exempted from being called a resident company even though it is incorporated in Ireland. Now,
subsidiary B makes themselves a tax resident of some other small nation like Cayman Island or Bermuda
but B will own all the nine US rights to intellectual property(as being a subsidiary of the US company).
The transaction takes place in this form that A will give for eg. Copyrights to B and B will give royalty fees
in return. After that, The B will then license the intellectual property rights to C in return for some
substantial royalty payments. C will then receive income from the use of the licensed assets in countries
outside the US. The transfer of the rights means that when subsidiary receives rights then it is enables to
receive all income from sales and use of the intellectual property outside of A’s home state and it
will go to C. Subsidiary C will then pay substantial royalties and licence fees to Subsidiary B for their
use of the intellectual property. This essentially transmits the majority of income to Subsidiary B,
where it can sit tax free in an offshore tax haven like Bermuda.
1. Finance Act 1999, s 23A(1)(a) (Ireland).
2. www.revenue.ie/en/about/foi/s16/income-tax-capital-gains-tax-corporation-tax/part-02/02-02-03.pdf
3. https://books.google.co.in/books?id=O4w5iDPFQMIC&pg=PA1231&lpg=PA1231&dq=Convention+Between+the+Government+of+Ir
eland+and+Government+of+the+United+States+of+America+for+the+Avoidance+of+Double+Taxation+and+the+Prevention+of+Fisc
al+Evasion+With+Respect+to+Taxes+on+Income+and+Capital+Gains,+Ireland-
United+States+%28signed+28+July+1997%29.&source=bl&ots=cBxcq1HaaX&sig=__HUgKFr4Sy7Iuz8lg1iDNKou8A&hl=en&sa=X&ei=S
mEIVezQKc2LuASi44GICQ&ved=0CCMQ6AEwAQ#v=onepage&q=Convention%20Between%20the%20Government%20of%20Ireland
%20and%20Government%20of%20the%20United%20States%20of%20America%20for%20the%20Avoidance%20of%20Double%20Ta
xation%20and%20the%20Prevention%20of%20Fiscal%20Evasion%20With%20Respect%20to%20Taxes%20on%20Income%20and%2
0Capital%20Gains%2C%20Ireland-United%20States%20(signed%2028%20July%201997).&f=false
5. These taxable profits would then be taxed at the prevailing Irish tax rate of 12.5% will be reduced by the
royalty payments of the first Irish company. However, this may not work if C is not considered as a fully
owned subsidiary of B. Hence, B and C can be treated as a single company for tax purposes.
Now, the Dutch sandwich or the introduction of a Dutch can further reduce the company’s tax liabilities
as A can set up a 3rd
subsidiary in Netherlands, lets say D, and bring it between the license and royalty
transaction process of B and C.
The factor here is that Ireland does not tax money being transferred among the EU neither Netherlands
levy any such tax and only charges a small amount of fee for using its tax system. This allows the royalty
payments to be transferred to the first Irish company virtually tax free except of the fee charged.
Source: www.businessinsider.com
6. Now the company set up in Netherlands can be a shell company. As the Irish subsidiary can continue its
operations, the Dutch one being in the middle can do nothing hence can save costs. But, the inference
made from this shell structure is that the Dutch division of A will not be productive which is not good for
Dutch economy and would be unfair as the Irish ones may be employing people but Dutch one would
not be.
What alternatively can be done is that US Company can directly transfer the IP to the Caribbean
entity and pay royalties directly to them. But the problem to this is that if they just incorporated in
the Caribbean and kept all their employees in the US, they would effectively have most of their
profits taxed in the US. Along with that a subsidiary requires large levels of employment which
would not have been possible in small island nations.
The company A makes a million dollar. Now, while intellectual property is being transferred, fair price
needs to be decided which is based on transfer pricing i.e. pricing within the subsidiaries which will be
fair but can be changed hence necessary be low. Profit margin going out of the home country due to this
and overseas profits ultimately ending up with the subsidiary in the tax haven will lead to the profit
portion in haven to be not taxed and hence company saves on the overall taxable income.
GOVERNMENT INTERVENTION
Ireland has announced that beginning in 2015, companies will have to be a tax resident to be
incorporated in Ireland, so the Double Irish tax strategy will no longer work quite as well as it has
because an Irish entity will no longer be able to be incorporated in a Caribbean nation. Still the
12.5% tax rate in Ireland will be better than the US tax rate. So companies can open a new venture
in Ireland and have less tax.
CONCLUSION
In short, companies transfer IP to Irish subsidiary and then transfer the royalties earned to an
Caribbean entity because Caribbean nations are tax havens!
The whole learning experience of this strategy was amazing as many facts were known during the
process worth knowing. Subsequently, we understand that many Indian companies or other
worldwide businesses can opt for tax saving strategies emerging from loopholes in law structure
but this particular strategy or any similar one could not have been utilized by any company of
nation other than US as the prime factor can be inferred as the exception of the US-Irish agreement
therefore this case has turned out to be specific.
We conclude with this strategy that measures to stop this arrangement are in the right direction.
However, considering this to be unethical is not appropriate as we consider it to be a mere utilization of
a loophole in law. Another argument that whether the companies following this earlier should be
penalized or re-taxed is not right as it is similar to the situations of arbitrage where flaws in laws govern
the actions.