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Article
Publication date: 2 November 2020

Ambareen Beebeejaun

The purpose of this paper is to analyze the Double Irish and Dutch Sandwich (DIDS) tax schemes used by international companies. Companies using these schemes are enabled to…

Abstract

Purpose

The purpose of this paper is to analyze the Double Irish and Dutch Sandwich (DIDS) tax schemes used by international companies. Companies using these schemes are enabled to transfer a large amount of their profits to offshore tax havens by using wholly owned subsidiaries located in Ireland and the Netherlands. This paper also analyzes the US General Anti-Avoidance Rule (GAAR) to see whether it can effectively detect and counteract this scheme. This analysis is furthermore enhanced by applying the Mauritian GAAR through Section 90 of the Income Tax Act to the said schemes.

Design/methodology/approach

Concerning research methods, the library and the internet will be the main sources of information to be used for this paper. Through the usage of library research, the Mauritian Income Tax Act, US GAAR, European Commission decisions and scholar writings will further enhance this paper on the structure and preventive actions that can be taken against the DIDS scheme. This paper will also use a case study coupled with a theoretical analysis of current anti-avoidance rules.

Findings

The paper then concludes that it is possible to counteract the schemes using the Mauritian law but under specific circumstances. It is then revealed that there is a fundamental flaw in the current tax systems, which is the inability to regulate the intangible nature of resources and technology-based transactions.

Originality/value

To the author's knowledge, this paper is among the first literature on the subject of DIDS strategies conducted in the context of Mauritius.

Open Access
Book part
Publication date: 17 August 2021

Mike Hynes

Abstract

Details

The Social, Cultural and Environmental Costs of Hyper-Connectivity: Sleeping Through the Revolution
Type: Book
ISBN: 978-1-83909-976-2

Expert briefing
Publication date: 13 July 2021

This framework laid out two pillars of reform. Pillar One would see large companies liable for tax in the end-market jurisdiction where their goods or services are used or…

Details

DOI: 10.1108/OXAN-DB262762

ISSN: 2633-304X

Keywords

Geographic
Topical
Article
Publication date: 2 July 2018

Akira Matsuoka

The purpose of this paper is to unveil the true background of the Base Erosion and Profit Shifting (BEPS) Project and to suggest crucial indexes for bringing a movement into a…

1903

Abstract

Purpose

The purpose of this paper is to unveil the true background of the Base Erosion and Profit Shifting (BEPS) Project and to suggest crucial indexes for bringing a movement into a future ceiling causing a struggle of the international tax system.

Design/methodology/approach

This paper looks into the historical context of this project before and after Starbucks’ scandal, comparing to other contexts of the international tax system. Also, this paper partially reviews BEPS from a legal perspective.

Findings

The key factors for building momentum of reform of international taxation are a country having a government willing to embrace the cause of reform, unfairness felt toward entities using tax avoidance schemes which other comparable entities could not be use, grass-roots pressure for the reform, effective places to negotiate cooperation among major countries for the reform, solid cooperation among many countries in the world to implement standards and rhetoric of slogan with less opposition.

Originality/value

The momentum of the reform of international taxation was analyzed before. But the BEPS Project has involved some unique events as compared with the Organization for Economic Cooperation and Development’s project on harmful tax practices, such as initiation of NGOs and boycott by consumers. Additionally, this paper will discuss insights, which the former research did not do.

Details

Journal of Financial Crime, vol. 25 no. 3
Type: Research Article
ISSN: 1359-0790

Keywords

Article
Publication date: 1 March 1990

Eileen Drew

The subject of part‐time work is one which has become increasingly important in industrialised economies where it accounts for a substantial and growing proportion of total…

Abstract

The subject of part‐time work is one which has become increasingly important in industrialised economies where it accounts for a substantial and growing proportion of total employment. It is estimated that in 1970, average annual hours worked per employee amounted to only 60% of those for 1870. Two major factors are attributed to explaining the underlying trend towards a reduction in working time: (a) the increase in the number of voluntary part‐time employees and (b) the decrease in average annual number of days worked per employee (Kok and de Neubourg, 1986). The authors noted that the growth rate of part‐time employment in many countries was greater than the corresponding rate of growth in full‐time employment.

Details

Equal Opportunities International, vol. 9 no. 3/4/5
Type: Research Article
ISSN: 0261-0159

Article
Publication date: 1 January 2006

Margery Stapleton, Helena Lenihan, Sheila Killian, Breda O'Sullivan and Kemmy Business

Under the Kyoto Protocol Ireland is committed to ensuring that its greenhouse gas emission levels are at or below 113 per cent of 1990 levels for the years 2008–2012. Irish

Abstract

Under the Kyoto Protocol Ireland is committed to ensuring that its greenhouse gas emission levels are at or below 113 per cent of 1990 levels for the years 2008–2012. Irish emissions have already exceeded this limit by approximately 10 to 15 per cent and must be reduced if the Kyoto Protocol targets are to be met. In this context, and drawing on relevant theory and research, this paper discusses the rationale for, and the potential impact of, government intervention in the market for carbon dioxide (CO2) emissions. The use of a Carbon Tax as a policy tool in reducing CO2 emissions is examined from both economic and taxation perspectives. Particular attention is paid to the Irish National Climate Change Strategy formulated in 2000 and the consultation process on implementing a Carbon Tax initiated by the Department of Finance in 2003. In September 2004 the Irish Government decided not to implement the proposed Carbon Tax. Submissions from interested parties on the carbon tax consultation process are reviewed against the rationale for implementation of such a tax. The body of evidence presented in this paper supports the implementation of a Carbon Tax—suggesting that the decision not to implement such a tax may have been a lost opportunity. The paper argues that a well‐designed Carbon Tax for Ireland, a simple levy on a close proxy for emissions, would be effective in influencing taxpayer behaviour bringing about a reduction in Ireland's CO2 emissions and supporting the polluter pays principle. In the absence of a carbon tax Ireland's Kyoto target is unlikely to be met and the consequent financial penalties will fall on all taxpayers. The paper concludes that the Irish Government should revisit this decision.

Details

Social Responsibility Journal, vol. 2 no. 1
Type: Research Article
ISSN: 1747-1117

Book part
Publication date: 1 March 2016

Shaen Corbet

This chapter examines the roles and challenges for the Irish economy in the aftermath of the collapse of the Celtic Tiger and the onset of the 2008 economic crisis. Specifically…

Abstract

Purpose

This chapter examines the roles and challenges for the Irish economy in the aftermath of the collapse of the Celtic Tiger and the onset of the 2008 economic crisis. Specifically, it does review the role that Government, the Central Bank of Ireland, and the Financial Regulator had before, during and after the collapse of both the Irish banking system and property market. This chapter explains the drivers behind the growth of the Celtic Tiger and the sources of leverage that amplified the severity of the subsequent collapse. Specifically, this chapter focuses on the changes that have since been made and provides a review of the lessons that can be obtained from the collapse.

Methodology/approach

The results presented in this chapter are based on analysis of secondary sources and a literature review to determine conceptual and theoretical frameworks for identifying the specific issues that the Irish economy endured since the 2008 economic crisis and the red flags and signals that were either missed or ignored.

Findings

Combined with the subprime collapse of 2007 and the international sovereign debt crisis evident since 2008, Ireland and the actions of its regulators and policy makers undoubtedly generated not only a catalyst to financial ruin, but also an incubator to aid its severity. The precise drivers that created the Celtic Tiger remained unchanged and played a significant role in the subsequent collapse. Banks were leveraged towards the Irish property market and the role of leverage in financial markets created mispricing, to which the basic principles of the efficient market hypothesis (EMH) failed. This miscalculation of risk was severe and destructive for the real economy. The reward for this error was a place in history as an ‘I’ in the derogatory term ‘PIIGS’.

Practical implications

This chapter could be used as teaching material for undergraduate and masters programmes in economics and finance. It provides a response to further understand the behaviour of the Irish economy during the development of the Celtic Tiger and the subsequent financial collapse that enveloped the Irish state.

Originality/value

This chapter discusses the role of leverage throughout a financial system and the necessity for financial monitors to promote an environment of sustainability and financial endurance; that which can survive an international financial crisis event.

Details

Lessons from the Great Recession: At the Crossroads of Sustainability and Recovery
Type: Book
ISBN: 978-1-78560-743-1

Keywords

Article
Publication date: 7 November 2016

Alan J. Gilmer, Mark J. McGarrity and Vivienne Byers

The purpose of this paper is to determine the status of policy design and policy implementation in the biofuel sector in Ireland. The focus of the work addresses the overarching…

Abstract

Purpose

The purpose of this paper is to determine the status of policy design and policy implementation in the biofuel sector in Ireland. The focus of the work addresses the overarching operational context of the biofuel sector in Ireland and the role of different actors in shaping and resolving inconsistencies in policy outlook and practice.

Design/methodology/approach

This study used a qualitative research approach involving a series of semi-structured interviews with members of the relevant sub-groups concerned. This study sought to address two questions – whether current or proposed policy is likely to affect consumption of indigenous biofuel feedstocks in the biofuel sector and what are the controlling factors in the demand for indigenous feedstocks for biofuel.

Findings

Outcomes suggest that while Irish government policy recognises the need to support the development of renewable energy, it also operates under a number of parallel and potentially inconsistent paradigms in relation to biofuels as a renewable energy commodity. It is contended that the outcome of this position is a lack of coherent and coordinated policy in the area of biofuel production, including second generation biofuel using indigenous feedstocks.

Originality/value

This paper provides a new cross sectoral perspective on the status of biofuel policy in Ireland with particular reference to second generation biofuel feedstocks. It focuses analysis on the nature of policy-operational inconsistencies and the need for a deeper ecological perspective in governance.

Details

International Journal of Energy Sector Management, vol. 10 no. 4
Type: Research Article
ISSN: 1750-6220

Keywords

Article
Publication date: 25 August 2023

Philip Cooke

The purpose here is to show how the “shadow” economy has grown in scale and impetus in recent years, though even before modern times it has been present (e.g. the City of London…

Abstract

Purpose

The purpose here is to show how the “shadow” economy has grown in scale and impetus in recent years, though even before modern times it has been present (e.g. the City of London, Shaxson, 2011) since at least the middle ages. The reasons for this have become complicated, but we can identify some “deep structures” that are common. Firstly, “globalisation” made it easier for multinationals to escape national regulatory regimes. Secondly, one of the ways neoliberal trading regulations allowed such actors to augment their assets was by means of what they initially called “transfer-pricing” but which now is officially known as “profit shifting” through tax havens. Thirdly, the growth in international trade in legal and illegal ways caused money laundering – even by otherwise respectable banks – to grow across borders. Conversely, from the supply-side, tax haven status was increasingly accessed by jurisdictions that sought to achieve economic growth by supplying tax haven services, both Delaware and Ireland as exemplars of a “developmental” fiscal policy.

Design/methodology/approach

This paper adopts a “pattern recognition” design, an approach that is abductive, meaning interpretive, as shown in the observation that explanation can be valid or reliable without direct observation. This is shown in the indirect observation that “rain fell because the terrace has puddles” or “ancient glaciers once carved this valley”.

Findings

Reviewing the European Union’s (EU) list of non-co-operating jurisdictions in support of the OECD’s review of base erosion and profit-shifting activity, Collin concluded the EU’s listing “moved the needle” somewhat but was only a modest success. This is because of its reluctance to sanction its own members or large economies like the USA. Data on foreign direct investment and offshore banking assets suggest listed jurisdictions did not suffer notably from being named and shamed. In all cases studied, this contribution found legally damaging, fraudulent, conflict of interest and corrupt practice activities everywhere.

Originality/value

The originality is found in three spheres. Firstly, the pattern recognition method was vindicated in yielding hard to research results. Secondly, the “assemblage-thirdspace” theory was found advantageous in demonstrating the uneven geography of tax haven clusters and their common history in turbocharging economic development. Finally, the empirics showed the ruses executed by cluster members in tax havens to circumvent the law from global management consultancies to micro-firms consisting of tax lawyers and other experts interacting in knowledge supply chains of dubious morality.

Details

Competitiveness Review: An International Business Journal , vol. ahead-of-print no. ahead-of-print
Type: Research Article
ISSN: 1059-5422

Keywords

Article
Publication date: 1 September 1963

WE are pleased to devote this Special Number of THE LIBRARY WORLD to a discussion of Irish libraries and librarianship. Our contributors are all distinguished members of the…

Abstract

WE are pleased to devote this Special Number of THE LIBRARY WORLD to a discussion of Irish libraries and librarianship. Our contributors are all distinguished members of the profession in Ireland, none more so than Dermot Foley, to whom we are greatly indebted for having convened this issue.

Details

New Library World, vol. 65 no. 3
Type: Research Article
ISSN: 0307-4803

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