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612-822-4611
Double Irish Arrangement

Double Irish Arrangement

Paperback

General Law

Currently unavailable to order

ISBN10: 6137177785
ISBN13: 9786137177785
Publisher: Miss Pr
Pages: 116
Weight: 0.40
Height: 0.28 Width: 5.98 Depth: 9.02
Language: English
Please note that the content of this book primarily consists of articles available from Wikipedia or other free sources online. The Double Irish Arrangement is a tax avoidance strategy that U.S. based multinational corporations use to lower their income tax liability. The idea is to use payments between related entities in a corporate structure to shift income from a higher-tax country to a lower-tax country. It relies on the fact that Irish tax law does not include effective transfer pricing rules. Typically, the company arranges for the rights to exploit intellectual property outside the United States to be owned by an offshore company. This is achieved by entering into a cost sharing agreement between the U.S. parent and the offshore company, in the terms of U.S. transfer pricing rules. The offshore company continues to receive all of the profits from exploitation of the rights outside the U.S., without paying U.S. tax on the profits unless and until they are remitted to the U.S.

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