We tell you here a widely used tax recipe: the double Irish with the Dutch sandwich. Discover this menu here.

Incorporation of an offshore company in Ireland and the Netherlands

Offshore havens in the heart of Europe

Taxation has become a determining element of the strategy of large multinationals, and it is increasingly common for them to use international tax planning to optimize your resources or what is commonly called pay less taxes.

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    The trap of the offshore company in Ireland and the Netherlands for trading

    SHowever, they are used in many cases by small and medium-sized companies E-commerce they put a offshore company in Ireland o Netherlands to sneakily reduce your tax bill from the tax haciendas of your home countries. Nothing is further from reality, since tax administrations and international organizations pursue these actions on a small scale through control measures and harsh economic sanctions for those who surprise by evading taxes.

    The Dutch sandwich and the Irish double, the daily menu of corporations


    he of the best-known and controversial systems to avoid paying taxes are the Dutch sandwich and the Irish double, through which technological multinationals, such as Google or Apple, save millions of euros in taxes in an absolutely legal way.

    It is a technique based on sending the profits first through an Irish company to a Dutch company, and then sending the capital to a second Irish company again. A simple strategy that has allowed large multinationals to reduce their tax obligations and that is one of the many that exist to protect the assets of companies from outside pressure from the Administrations. Both work in combination. On the one hand, the double Irish allows the transfer of the profits of these companies to territories with low or no taxation, or rather, to tax havens.

    What tax havens do the large companies of the Ibex35 use?


    elaware, Holland and Ireland are the paraΓ­sos fiscales most used by companies in the Spanish Ibex 35 index to create offshore companies and move its subsidiaries there. From 2009 to 2014, their subsidiaries increased 227%, from 272 to 891 subsidiaries.

    This is the case, for example, of Ikea, Starbucks, Google, Microsoft,  Apple or Facebook, which through certain gaps or legal loopholes in these countries benefit from little or no taxation in some cases.

    To do this, they use some strategies aggressive tax planning, thus classified by the rest of the partners of the European Union and by other countries of the world, since they consider them to be unfair competition.

    Dutch and double Irish sandwich: this is how the multinationals avoid taxes


    unites by creating a offshore company in Ireland and another based in a low tax territory, the latter being the owner of the intellectual rights. The Irish parent company will be responsible for marketing the company's products and receiving revenue from around the world. The latter pays huge amounts to the company located in the tax haven for the use of intellectual rights, which means that the benefits taxed in Ireland are scarce. Combined with thedutch sandwich It is also allowed to avoid the payment of benefits in Ireland through the payment of "royalties" to a company incorporated in the Netherlands.

    As we have seen, one of the sectors that uses these techniques is technology, since these companies can transfer a large part of their profits to other countries by locating intellectual property rights in any foreign subsidiary where they want to direct profits. . Some considered techniques of aggressive tax planningand that they have come under harsh criticism from the United States and the European Union when they discovered that billions of euros can be moved exempt from taxes.

    Last 2015, Ireland changed its legislation to eliminate the Irish doubleHowever, companies that already operated it in the country will be able to continue practicing it until 2020, long enough for a new tax system to be created at some point. tax haven for the companies.

    What type of private banking exists in Ireland and the Netherlands?

    Fight aggressive tax planning


    In recent years, the need to prevent and combat the practices of aggressive tax planning It has played a central role on the agenda of the main organizations such as the OECD or the European Union, as well as the tax administrations of the different countries, such as the United States, through FATCA.

    The OECD has spent years developing a complementary cooperative tax compliance model, aimed at preventing fraud, tax avoidance and aggressive tax planning.

    Anti-holding measures for European offshore companies

    The Erosion of the Tax Base and the Transfer of Profits (BEPS) Project is a Reform of the international tax system to curb tax avoidance by large multinationals. It provides the different states with solutions to limit the "normative gaps", existing at the international level that allow the profits of the companies to disappear or be transferred to jurisdictions with low or no taxation, where an economic activity is not carried out.

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