Talk:Double Irish arrangement/Archive 1

Archive 1

LOL at the countermeasures section

That says it all doesn't it? — Preceding unsigned comment added by 85.210.45.177 (talk) 22:47, 21 April 2013 (UTC)

Too General

More specific details on exactly how these arrangements work are desired. The specific laws & statutes & tax codes used, the papers that must be filed (the forms and their sources), the fees required (if any), plus several specific, complete real-world examples of how such schemes are setup, with step-by-step instructions would be swell. Arrangements that use different countries (if any) are also of interest. A list of corporations (and any person or thing) using these rules, with lots of financial details and the amounts of tax saved would be interesting. . . . Ace Frahm (talk) 20:29, 22 October 2010 (UTC)

It is interesting, but Wikipedia is not a manual. People who wish to dodge taxes should instead consult a knowledgeable tax lawyer. Br, Jt (talk) 19:59, 26 March 2011 (UTC)

The point isn't to DO IT, the point is to understand how it is being used against us, so we can end the practices. This requires expert knowledge that the article lacks. Ace Frahm (talk) 10:13, 24 April 2013 (UTC)

I agree with the idea that more details are better, and that can be done without creating a "manual".Jonny Quick (talk) 18:01, 13 May 2013 (UTC)

US references?

References to the United States in this article make it unnecessarily confusing and too specific. For example, a double Irish scheme might be used by an Australian company. Please consider removing them. — Preceding unsigned comment added by 122.108.160.83 (talk) 09:41, 15 July 2013 (UTC)

Tag added. Murry1975 (talk) 10:01, 15 July 2013 (UTC)

Re-added. Despite being pioneered by US companies selling products/services to US customers it's a global issue and the article should better reflect that.

Suggest that perhaps a short "History" section be added which would naturally focus one it's US-based beginnings. -Oosh (talk) 04:53, 29 September 2014 (UTC)

Apple' role in creating the double irish

From the bottom of the page, under references is this little snippet: "In the late 1980s, Apple was among the pioneers in creating a tax structure — known as the Double Irish — that allowed the company to move profits into tax havens around the world ..." Perhaps this should be mentioned in the article, compared to historical tax avoidance schemes?

74.73.54.107 (talk) 19:46, 21 May 2013 (UTC)

Thanks for the idea. I added it. New worl (talk) 04:11, 22 May 2013 (UTC)

The claim is dubious, the source doesn't give any true information on how this conclusion was made, and all other cites on the web refer back to this article. 91.195.79.7 (talk) 15:27, 15 October 2014 (UTC)

"Particularly Odious"

I've removed the words "particularly odious" from the State Aid section. The case isn't over and even if it was, it's not appropriate language for a Wikipedia article, given the wide range of opinions on the matter. — Preceding unsigned comment added by 37.228.251.216 (talk) 10:54, 24 February 2017 (UTC)

Single Malt

Hello !

I have just added a section on the new Single Malt arrangement which replaced the Double Irish almost immediately in 2015. I don't think we need a separate article on Single Malt as its structure is effectively identical to the double irish. There are some great graphs and structure diagrams in the Christian Aid report that I would love to use but I don't have the skill level to incorporate (and not sure if it violates copyright) ? All comments welcome ! Britishfinance (talk) 14:01, 21 March 2018 (UTC)

Re-writing parts of this article again to simplify and reduce text (and also increase references). hopefully of interest and use. Britishfinance (talk) 17:07, 23 April 2018 (UTC)

Name

Not a native speaker: What are the origins of that rather strange expression "double irish (with a dutch sandwich)"? Is it an innuendo?--Antemister (talk) 19:45, 20 October 2018 (UTC)

Double Irish is a play on the fact that the system needs two Irish companies to work (IRL1 and IRL2), and is a play on the Irish Whiskey term ("a shot of double Irish"). Ironically, Apple did not use a classical Double Irish and tried to execute the structure using one company (with two internal branches), and got fined 13bn. The Dutch Sandwich does not refer to any particular Dutch food item, but just that the Dutch component of the tax structure is "sandwiched" into the Double Irish structure. Britishfinance (talk) 19:55, 20 October 2018 (UTC)

OK, thanks, already guessed that it might refer to something alcoholic (no knowledge on that topic...). That expression starts to make sense.--Antemister (talk) 20:06, 20 October 2018 (UTC)

Dashes vs hyphens

Please review the manual of style. Whoever wrote the bulk of the text in this article improperly used dashes for compound adjectives instead of hyphens, and improperly used dashes to attach adjectives to the nouns they are modifying. It makes the article read very poorly to see such fundamental errors of basic English usage in an otherwise well researched article. I attempted to mollify it somewhat, but it really needs a more thorough copy editing that I have time for at this moment. oknazevad (talk) 14:20, 10 November 2018 (UTC)

Sorry, my fault on that count. I have written most of this article as well. Thanks for your input and will review the MOS and try and fix this too. Britishfinance (talk) 14:45, 10 November 2018 (UTC)

Do these structures exist elsewhere

Do Luxembourg and Singapore have versions of these tax structures? — Preceding unsigned comment added by 31.187.0.241 (talk) 12:32, 29 January 2019 (UTC)

Luxembourg does not really have BEPS tools of Ireland’s standard, it is more like a traditional Caribbean tax haven in that regard (eg SPVs etc). The U.K. has some versions but not as strong as Ireland as they are wary of damaging their own indigenous corporate tax base (Ireland’s tax take from major Irish indigenous corporations is quite modest, particularly as its banks don’t pay tax due to accumulated losses from the Irish financial crisis); that could change after Brexit when the U.K. will be free(er) of EU rules on competition (how the EU enforces tax law), and could upgrade them.

The big competition to Ireland is from Singapore, who have their own CAIA scheme (hence why Dyson has moved to Singapore; they could not move to Ireland (i.e. within the EU) given James Dyson's public stance in favor of Brexit; Dyson's effective rate of tax in Singapore will be closer to zero, and not the headline rate of 17%). The new OECD rules will make Singapore and Ireland the two most attractive/powerful tax havens in the world for any corporation who can create large IP-assets (tech, life sciences, patented etc.), at the expense of the Caribbean havens (and obviously higher-tax economies). Britishfinance (talk) 14:14, 29 January 2019 (UTC)

Untitled

This is a site with some more information about his work: http://www.imdb.com/name/nm0001402/

Leonardo Fontenelle - — Preceding unsigned comment added by 201.8.138.252 (talk • contribs) 01:37, 17 May 2004 (UTC)

Mention of this article on the CoFR website as good source

From the Council on Foreign Relations website: "The best source I have found for all this is Wikipedia [a link is given to this article]. The jargon can be daunting ("CAIA", "BEPS"), but the result is clear enough—a very low effective tax rate (emphasis added)." [1]. Britishfinance (talk) 13:52, 1 March 2019 (UTC)

Attack editing

This article has been targeted, on the “grounds” that it is unfair to Ireland. But it is about a famous Ireland-related tax “management” technique, so this makes no sense. If there are further attacks, I think some semi-protection might be appropriate...SeoR (talk) 18:48, 16 April 2019 (UTC)

I would support that. It tends to be ignored for long periods but then gets hit. If it is not being watched, it will revert back to its sub-encyclopedic state. Britishfinance (talk) 18:53, 16 April 2019 (UTC)

A Commons file used on this page has been nominated for deletion

The following Wikimedia Commons file used on this page has been nominated for deletion:

• James R. Hines Jr. C-SPAN.jpg

Participate in the deletion discussion at the nomination page. —Community Tech bot (talk) 11:07, 24 November 2019 (UTC)