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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.

Abstract

Details

A Circular Argument
Type: Book
ISBN: 978-1-80071-385-7

Article
Publication date: 1 February 1996

Richard A.E. North, Jim P. Duguid and Michael A. Sheard

Describes a study to measure the quality of service provided by food‐poisoning surveillance agencies in England and Wales in terms of the requirements of a representative consumer…

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Abstract

Describes a study to measure the quality of service provided by food‐poisoning surveillance agencies in England and Wales in terms of the requirements of a representative consumer ‐ the egg producing industry ‐ adopting “egg associated” outbreak investigation reports as the reference output. Defines and makes use of four primary performance indicators: accessibility of information; completeness of evidence supplied in food‐poisoning outbreak investigation reports as to the sources of infection in “egg‐associated” outbreaks; timeliness of information published; and utility of information and advice aimed at preventing or controlling food poisoning. Finds that quality expectations in each parameter measured are not met. Examines reasons why surveillance agencies have not delivered the quality demanded. Makes use of detailed case studies to illustrate inadequacies of current practice. Attributes failure to deliver “accessibility” to a lack of recognition on the status or nature of “consumers”, combined with a self‐maintenance motivation of the part of the surveillance agencies. Finds that failures to deliver “completeness” and “utility” may result from the same defects which give rise to the lack of “accessibility” in that, failing to recognize the consumers of a public service for what they are, the agencies feel no need to provide them with the data they require. The research indicates that self‐maintenance by scientific epidemiologists may introduce biases which when combined with a politically inspired need to transfer responsibility for food‐poisoning outbreaks, skew the conduct of investigations and their conclusions. Contends that this is compounded by serious and multiple inadequacies in the conduct of investigations, arising at least in part from the lack of training and relative inexperience of investigators, the whole conditioned by interdisciplinary rivalry between the professional groups staffing the different agencies. Finds that in addition failures to exploit or develop epidemiological technologies has affected the ability of investigators to resolve the uncertainties identified. Makes recommendations directed at improving the performance of the surveillance agencies which, if adopted will substantially enhance food poisoning control efforts.

Details

British Food Journal, vol. 98 no. 2/3
Type: Research Article
ISSN: 0007-070X

Keywords

Article
Publication date: 23 January 2007

Martin J. Tenpierik, Johannes J.M. Cauberg and Thomas I. Thorsell

Although vacuum insulation panels (VIPs) are thermal insulators that combine high thermal performance with limited thickness, application in the building sector is still rare due…

4376

Abstract

Purpose

Although vacuum insulation panels (VIPs) are thermal insulators that combine high thermal performance with limited thickness, application in the building sector is still rare due to lack of scientific knowledge on the behaviour of these panels applied in building constructions. This paper, therefore, seeks to give an overview of the requirements for and the behaviour of VIPs integrated into building components and constructions. Moreover, the interaction between different requirements on and properties of these integrated components are discussed in detail, since a desired high quality of the finished product demands an integral approach regarding all properties and requirements, especially during the design phase. Therefore, the importance of an integral design approach to application of VIPs is shown and emphasized in this paper.

Design/methodology/approach

To achieve this objective, the legally and technically required properties of VIPs and especially their interrelationships have been studied, resulting in a relationship diagram. Based on these investigations of thermal‐ , service life‐ and structural‐properties have been selected to be studied more elaborately using experimental set‐up for structural testing and simulation software for thermal and hygrothermal testing.

Findings

Two relationships between requirements or properties were found to be of principal importance for the design of façade components in which VIPs are integrated. First, thermal performance requirements strongly interact with structural performance, principally through the edge spacer of this façade component. A high thermal performance requires minimization of the thermal edge effect, in most cases reducing the structural performance of the entire panel. Second, an important relationship between thermal performance and service life has been recognised. The operating phenomenon mainly governing this interaction is thermal conductivity aging.

Originality/value

Most research in the field of vacuum insulation until now has been directed towards gaining knowledge on specific properties of the product, especially on thermal and hygrothermal properties. The relationships and interactions between these properties and the structural behaviour, however, have been neglected. This paper, therefore, addresses the need for an integral design (and study) approach for the application of VIPs in architectural constructions.

Details

Construction Innovation, vol. 7 no. 1
Type: Research Article
ISSN: 1471-4175

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 April 1980

The lengthy review of the Food Standards Committee of this, agreed by all public analysts and enforcement officers, as the most complicated and difficult of food groups subject to…

Abstract

The lengthy review of the Food Standards Committee of this, agreed by all public analysts and enforcement officers, as the most complicated and difficult of food groups subject to detailed legislative control, is at last complete and the Committee's findings set out in their Report. When in 1975 they were requested to investigate the workings of the legislation, the problems of control were already apparent and getting worse. The triology of Regulations of 1967 seemed comprehensive at the time, perhaps as we ventured to suggest a little too comprehensive for a rational system of control for arguments on meat contents of different products, descriptions and interpretation generally quickly appeared. The system, for all its detail, provided too many loopholes through which manufacturers drove the proverbial “carriage and pair”. As meat products have increased in range and the constantly rising price of meat, the “major ingredient”, the number of samples taken for analysis has risen and now usually constitutes about one‐quarter of the total for the year, with sausages, prepared meats (pies, pasties), and most recently, minced meat predominating. Just as serial sampling and analysis of sausages before the 1967 Regulations were pleaded in courts to establish usage in the matter of meat content, so with minced meat the same methods are being used to establish a maximum fat content usage. What concerns food law enforcement agencies is that despite the years that the standards imposed by the 1967 Regulations have been in force, the number of infringements show no sign of reduction. This should not really surprise us; there are even longer periods of failures to comply; eg., in the use of preservatives which have been controlled since 1925! What a number of public analysts have christened the “beefburger saga” took its rise post‐1967 and shows every indication of continuing into the distant future. Manufacturers appear to be trying numerous ploys to reduce the content below the Regulation 80% mainly by giving their products new names. Each year, public analysts report a flux of new names and ingenious defences; eg, “caterburgers” and similar concocted nomenclature, and the defence that because the name does not incorporate a meat, it is outside the statutory standard.

Details

British Food Journal, vol. 82 no. 4
Type: Research Article
ISSN: 0007-070X

Article
Publication date: 1 February 1973

The new Fair Trading measure aims at the establishment of a strong, bioadly‐based central direction of consumer protection; a new Director‐General of Fair Trading with wide…

Abstract

The new Fair Trading measure aims at the establishment of a strong, bioadly‐based central direction of consumer protection; a new Director‐General of Fair Trading with wide responsibilities “for protecting consumers” with authority to “make proposals for the exercise of order‐making powers in relation to trading practices which adversely affect consumer interests”, and “to act against those who persistently follow a course of conduct unfair to consumers”. This supremo is to work closely with the Monopolies and Mergers Commission and the Restrictive Practices Board, and no less than five junior Ministers are to be given special responsibilities for protecting consumer interests, handling these aspects of the new system in their own departments.

Details

British Food Journal, vol. 75 no. 2
Type: Research Article
ISSN: 0007-070X

Article
Publication date: 1 March 1977

One of the most serious problems facing the country today is maintaining dietary standards, especially in the vulnerable groups, in the face of rising food prices. If it were food…

Abstract

One of the most serious problems facing the country today is maintaining dietary standards, especially in the vulnerable groups, in the face of rising food prices. If it were food prices alone, household budgetry could cope, but much as rising food prices take from the housewife's purse, rates, fuel, travel and the like seem to take more; for food, it is normally pence, but for the others, it is pounds! The Price Commission is often accused of being a watch‐dog which barks but rarely if ever bites and when it attempts to do this, like as not, Union power prevents any help to the housewife. There would be far less grumbling and complaining by consumers if they could see value for their money; they only see themselves constantly overcharged and, in fact, cheated all along the line. In past issues, BFJ has commented on the price vagaries in the greengrocery trade, especially the prices of fresh fruit and vegetables. Living in a part of the country given over to fruit farming and field vegetable crops, it is impossible to remain unaware of what goes on in this sector of the food trade. Unprecedented prosperity among the growers; and where fruit‐farming is combined with field crops, potatoes, cabbage, cauliflower and leafy brassicas, many of the more simple growers find the sums involved frightening. The wholesalers and middle‐men are something of unknown entities, but the prices in the shops are there for all to see. The findings of an investigation by the Commission into the trade, the profit margins between wholesale prices and greengrocers' selling prices, published in February last, were therefore not altogether surprising. The survey into prices and profits covered five basic vegetables and was ordered by the present Prices Secretary the previous November. Prices for September to November were monitored for the vegetables—cabbages, brussels sprouts, cauliflowers, carrots, turnips and swedes, the last priced together. Potatoes were already being monitored.

Details

British Food Journal, vol. 79 no. 3
Type: Research Article
ISSN: 0007-070X

Article
Publication date: 1 October 1995

Martin Fojt

This special “Anbar Abstracts” issue of the Marketing Intelligence & Planning is split into nine sections covering abstracts under the following headings: Marketing Strategy;…

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Abstract

This special “Anbar Abstracts” issue of the Marketing Intelligence & Planning is split into nine sections covering abstracts under the following headings: Marketing Strategy; Customer Service; Sales Management/Sundry; Promotion; Marketing Research/Customer Behaviour; Product Management; Logistics and Distribution.

Details

Marketing Intelligence & Planning, vol. 13 no. 10
Type: Research Article
ISSN: 0263-4503

Article
Publication date: 1 March 1984

“Consumerism”, for want of a better description, is given to the mass of statutory control (which shows no sign of declining) of standards, trading justice to the consumer, means…

Abstract

“Consumerism”, for want of a better description, is given to the mass of statutory control (which shows no sign of declining) of standards, trading justice to the consumer, means of redress to those who have been misled and defrauded, advice to those in doubt; and to the widespread movement, mostly in the Western world, to achieve these ends.

Details

British Food Journal, vol. 86 no. 3
Type: Research Article
ISSN: 0007-070X

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