• 목록
• 답변
• 글쓰기
• 게시판 리스트 옵션
  • 수정
  • 삭제

Introduction:
The Irish Dutch Sandwich is a tax strategy that involves routing money through subsidiaries in Ireland and the Netherlands to minimize tax liabilities. This report aims to provide a detailed analysis of the concept, its legal framework, and its implications on tax avoidance.

What is the Irish Dutch Sandwich?
The Irish Dutch Sandwich is a popular tax planning method used by multinational corporations to reduce their tax burdens. It involves establishing a subsidiary company in Ireland, which then transfers royalties or intellectual property rights to another subsidiary in the Netherlands. Finally, the profits are funneled to a third offshore subsidiary located in a tax haven jurisdiction.

Legal Framework:
This tax strategy relies on the differences in tax laws between Ireland and the Netherlands. Ireland offers a favorable tax regime with a low corporate tax rate of 12.5%, while the Netherlands has a set of tax treaties that allow for tax-efficient routing of funds. By exploiting these legal frameworks, companies can significantly reduce their overall tax liabilities.

Benefits and Implications:
The primary benefit of the Irish Dutch Sandwich is the reduction of tax obligations. By utilizing the low corporate tax rate in Ireland and the advantageous tax treaties in the Netherlands, companies can legally minimize their tax payments. This can result in substantial savings, leading to increased profits and shareholder value.

However, it is crucial to note that while this strategy is legal, it can be seen as aggressive tax planning or even tax avoidance. The Irish Dutch Sandwich has faced criticism for enabling multinational corporations to shift profits to low-tax jurisdictions and ultimately reducing the tax revenues of other countries.

International Response:
The European Union and various individual countries have taken steps to combat aggressive tax planning. The EU has introduced measures to increase tax transparency and combat tax avoidance, including the Anti-Tax Avoidance Directive. Additionally, countries such as the United States have implemented tax reforms to limit the benefits of strategies like the Irish Dutch Sandwich.

Challenges and Limitations:
While the Irish Dutch Sandwich has been a widely used tax strategy, recent international efforts to combat tax avoidance have imposed limitations on its effectiveness. Countries are strengthening their tax laws and increasing their scrutiny of aggressive tax planning methods. As a result, the effectiveness and sustainability of the Irish Dutch Sandwich may decrease over time.

Conclusion:
The Irish Dutch Sandwich has gained popularity as a tax planning strategy due to the favorable tax regimes in Ireland and the Netherlands. While it offers companies significant tax savings, it is important to recognize the potential ethical concerns associated with aggressive tax planning. As international efforts to combat tax avoidance continue to evolve, the longevity of the Irish Dutch Sandwich strategy may be limited.