The double Irish arrangement is a tax strategy, that some multinational corporations used to lower their corporate tax liability, it relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions, the standard rate of corporation tax is among the lowest in the world at 12.5%, in Ireland there is an income tax, a value added tax (VAT), and various other taxes, is called?
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Double Irish arrangement The double Irish arrangement is a tax strategy that some multinational corporations used to lower their corporate tax liability. The strategy has ceased to be available since 1 January 2015, though those already engaging in the arrangement have until 2020 to find another arrangement. The strategy used payments between related entities in a corporate structure to move income from a higher-tax country to a lower or no tax jurisdiction. It relies on the fact that Irish tax law does not include transfer pricing rules as does the United States and those of many other jurisdictions. Specifically, Ireland has territorial taxation, and does not levy taxes on income booked in subsidiaries of Irish companies that are outside the state.
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Taxation in the Republic of Ireland In Ireland there is an income tax, a value added tax (VAT), and various other taxes. Employees pay pay-as-you-earn (PAYE) taxes based on their income, less certain allowances. The taxation of earnings is progressive, with little or no income tax paid by low earners and a high rate applied to middle to top earners, the top marginal rate of tax (including USC and PRSI) is 52%. However a large proportion of central government tax revenue is also derived from VAT, excise duties and other taxes on consumption. The standard rate of corporation tax is among the lowest in the world at 12.5%.
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Vehicle registration tax (Ireland) Vehicle registration tax or VRT is a tax that must be paid in Ireland when registering a motor vehicle.
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Securities turnover excise tax A securities turnover excise tax (STET) is a small tax on every stock, swap, derivative, or other trade. It has been levied historically in the United States and has been proposed more recently as a way to reduce speculation in financial markets.
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Tax consolidation Tax consolidation, or combined reporting, is a regime adopted in the tax or revenue legislation of a number of countries which treats a group of wholly owned or majority-owned companies and other entities (such as trusts and partnerships) as a single entity for tax purposes. This generally means that the head entity of the group is responsible for all or most of the group's tax obligations (such as paying tax and lodging tax returns). Consolidation is usually an all-or-nothing event: once the decision to consolidate has been made, companies are irrevocably bound. Only by having less than a 100% interest in a subsidiary can that subsidiary be left out of the consolidation.
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Taxation of trusts (United Kingdom) The taxation of trusts in the United Kingdom is governed by a different set of principles to those tax laws which apply to individuals or companies.
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Base erosion and profit shifting Base erosion and profit shifting (BEPS) refers to tax planning strategies used by multinational companies, that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity.The project headed by the OECD was initiated by the G20 in 2012.
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Income tax in the United States In the United States, a tax is imposed on income by the federal government, most state governments, and many local governments. The income tax is determined by applying a tax rate, which may increase as income increases, to taxable income as defined. Individuals and corporations are directly taxable, and estates and trusts may be taxable on undistributed income.
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Flat tax A flat tax (short for flat tax rate) is a tax system with a constant marginal rate, usually applied to individual or corporate income. A true flat tax would be a proportional tax, but implementations are often progressive and sometimes regressive depending on deductions and exemptions in the tax base. There are various tax systems that are labeled "flat tax" even though they are significantly different.
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Tax pooling Tax pooling allows New Zealand taxpayers to pool their provisional tax payments together in an account held by a registered tax pooling intermediary at Inland Revenue (IRD) so that underpayments by some can be offset by overpayments of others. Taxpayers receive/pay an interest rate that is higher/lower than IRD’s rates if they overpay/underpay provisional tax. Intermediaries operate under legislation set out in the Income Tax Act 2007 and Tax Administration Act 1994.
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Transfer mispricing Transfer mispricing, also known as transfer pricing manipulation or fraudulent transfer pricing, refers to trade between related parties at prices meant to manipulate markets or to deceive tax authorities. The legality of the process varies between tax jurisdictions; most regard it as a type of fraud or tax evasion.
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Corporation Tax Act 2009 The Corporation Tax Act 2009 (c 4) is an Act of the Parliament of the United Kingdom. It restated certain legislation relating to corporation tax, with minor changes that were mainly intended "to clarify existing provisions, make them consistent or bring the law into line with well established practice." The Bill was the work of the Tax Law Rewrite Project team at HM Revenue and Customs.
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Alternative minimum tax The alternative minimum tax (AMT) is a supplemental income tax imposed by the United States federal government required in addition to baseline income tax for certain individuals, corporations, estates, and trusts that have exemptions or special circumstances allowing for lower payments of standard income tax. AMT is imposed at a nearly flat rate on an adjusted amount of taxable income above a certain threshold (also known as exemption). This exemption is substantially higher than the exemption from regular income tax.
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Flow-through entity A flow-through entity (FTE) is a legal entity where income "flows through" to investors or owners; that is, the income of the entity is treated as the income of the investors or owners. Flow-through entities are also known as pass-through entities or fiscally-transparent entities. Depending on the local tax regulations, this structure can avoid dividend tax and double taxation because only owners or investors are taxed on the revenue. Technically, for tax purposes, flow-through entities are considered "non-entities" because they are not taxed; rather, taxation "flows-through" to another tax return.
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Value added In business, the difference between the sale price and the production cost of a product is the unit profit. In economics, the sum of the unit profit, the unit depreciation cost, and the unit labor cost is the unit value added. Summing value added per unit over all units sold is total value added. Total value added is equivalent to revenue less intermediate consumption. Value added is a higher portion of revenue for integrated companies, e.g., manufacturing companies, and a lower portion of revenue for less integrated companies, e.g., retail companies. Total value added is very closely approximated by compensation of employees plus earnings before taxes. The first component is a return to labor and the second component is a return to capital. In national accounts used in macroeconomics, it refers to the contribution of the factors of production, i.e., capital (e.g., land and capital goods) and labor, to raising the value of a product and corresponds to the incomes received by the owners of these factors. The national value added is shared between capital and labor (as the factors of production), and this sharing gives rise to issues of distribution.
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Air Travel Tax The Air Travel Tax was an Irish tax applied to flights departing from airports in Ireland. It was introduced in the 2009 Budget. Until 28 February 2011, there were two rates of tax, €10 for each passenger flying to an airport more than 300 km from Dublin Airport, and €2 per passenger flying to any other airport within 300 km. As the differential rate was considered by the EU to be an interference with the internal market, this was changed to a flat rate of €3 from 1 March 2011. The tax was opposed by airlines and the tourism industry. Transit passengers are excluded.
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Private copying levy A private copying levy (also known as blank media tax or levy) is a government-mandated scheme in which a special tax or levy (additional to any general sales tax) is charged on purchases of recordable media. Such taxes are in place in various countries and the income is typically allocated to the developers of "content". (A distinction is sometimes made between "tax" and "levy" based on the recipient of the accumulated funds; taxes are received by a government, while levies are received by a private body, such as a copyright collective.)
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Transfer payment In economics, a transfer payment (or government transfer or simply transfer) is a redistribution of income and wealth (payment) made without goods or services being received in return. These payments are considered to be non-exhaustive because they do not directly absorb resources or create output. Examples of transfer payments include welfare (financial aid), social security, and government making subsidies for certain businesses (firms).
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Tax holiday A tax holiday is a temporary reduction or elimination of a tax. It is synonymous with tax abatement, tax subsidy or tax reduction. Governments usually create tax holidays as incentives for business investment. Tax holidays have been granted by governments at national, sub-national, and local levels, and have included income, property, sales, VAT, and other taxes. Some tax holidays are extra-statutory concessions, where governing bodies grant a reduction in tax that is not necessarily authorized within the law. In developing countries, governments sometimes reduce or eliminate corporate taxes for the purpose of attracting foreign direct investment or stimulating growth in selected industries.
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Commuter tax A commuter tax is a tax (generally on either income or wages) levied upon persons who work, but do not live, in a particular jurisdiction. The argument for a commuter tax is that it pays for public services, such as police, fire, and sanitation, received by and beneficial to people who work within the jurisdiction levying the commuter tax. Arguments against such a tax are that it acts as an incentive for businesses to relocate outside of the jurisdiction, along with their residents. In some cases, individual cities may be barred from enacting a commuter tax even though the state governments may impose a non-resident income tax. States may choose to enter "reciprocal tax agreements" to exempt non-residents from some local taxes.
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Domestic international sales corporation The domestic international sales corporation is a provision unique to tax law in the United States. In 1971, the U.S. Congress voted to subsidize exports of U.S. made goods through the income tax law. The initial mechanism was through a Domestic International Sales Corporation (DISC), an entity with no substance which received tax benefits. Today, shareholders of a DISC continue to receive reduced income tax rates on qualifying income from exports of U.S. made goods.
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Two-tiered pricing Two-tiered pricing refers to a system under which commodities for domestic use are supported at one level and those for export markets at another, lower level.