...the US, Irish, Dutch and Caribbean tax systems facilitate MNC’s in minimising their global tax bills? In order to minimise their global tax bills, MNC’s engage in a tax avoidance technique known as the ‘Double Irish with a Dutch Sandwich technique’. It is a technique employed by certain large corporations, involving the use of a combination of Irish and Dutch subsidiary companies to shift profits to low or no tax jurisdictions. In this essay I am going to explore this tax avoidance technique and give a step-by-step guide as to how large MNC’s such as Google use it. First I am going to give an overview of this tax avoidance technique and why it is advantageous for an MNC to use. This technique is just one of a class of similar international tax avoidance schemes that has allowed MNC’s to dramatically reduce their overall corporate tax rates. It in essence involves sending profits through one Irish company, to a Dutch company and finally to a second Irish company headquartered in a tax haven. These techniques are most prominently used by technology companies because these firms can easily shift large portions of profits to other countries by assigning intellectual property rights to subsidiaries abroad. Each step in the ‘double Irish with a Dutch sandwich’ technique involves arranging transactions between subsidiary companies to take advantage of the idiosyncrasies of varied national tax codes. For decades MNC’s have been taking advantage of the ‘quirk’ in the Irish tax law...
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...by expanding and add greater stability to earnings through diversification. Complex organizational structures help achieve business objectives such as increased profitability and reduced risks. Also, these complex structures allow the company to reduce its overall tax burden. One such strategy is discussed in this paper. Transfer pricing allows the company to price the inter-company transactions. Transfer pricing simplifies the accounting of transactions that take place between affiliated or related entities. Companies have freedom in valuing inter-company transactions. But, if strategically implemented, this strategy allows the company to save taxes and retain large amount of profits. Keywords: Transfer mispricing, tax-havens, Double Irish Dutch Arrangement Transfer Pricing Transfer pricing is the methodology used to set the prices for goods sold or services provided between related entities within an enterprise. Related entities are those which are under control of a single corporation and include branches and companies that are wholly or majority owned ultimately by the parent company. Generally, such a transfer price should be equal to the price which the entity would charge to an independent customer, an arm’s length customer. Such a price is termed as an “arm’s length price” (Transfer Pricing, Wikipedia, 2015). Financial accounting does not differentiate between affiliates and treats the corporate group as a single entity. But the federal income tax law treats affiliates...
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...What is tax haven? Why are all tycoons so crush on them? In January 9, 2015, Cheung Kong Holdings Limited announced the restructuring arrangement of combining Cheung Kong Holdings and Hutchison Whampoa to form a new listed company: “CK Hutchison Holdings Limited”. This newly established company is incorporated at Cayman Islands (SCMP, 2015) which has been commonly known as “tax haven”. As the name implies, tax haven is a place where levy taxes at a very low rate or even not at all to companies registered there. It has been an interesting phenomenon that most of the largest corporations in the world, they are not registered at the place where they operate their major business or make most of the profits. Indeed, how is this mechanism works? How could the multi-national corporations in the world transfer their profits made all over the world to these tax havens to avoid tax? Advantages of tax havens If we look at the figures provided by HKEX in 2013, 724 out of 1602 companies listed in Hong Kong Stock Exchange market are incorporated in Cayman Islands (881903, 2015). This has indicated that it has already been a common practice for listed companies to be registered in these offshore financial centre. Take Cayman Islands as an example, being one of the most popular tax havens in the world, not only it has a no profit tax levied, but also it comes with much looser company law and other financial regulations. For the investors who want to register a company in Cayman Islands...
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...The objective of this paper is to argue the need for tax reforms specifically aimed at addressing global issues in an increasingly interconnected world where tax laws are not designed for the digital age. It highlights the issues faced by countries due to ‘Base Erosion Profit Shifting ‘. The emphasis is mainly on two taxes, namely, ‘Diverted Profit Tax’ and ‘Digital Goods and Service Tax’, which are recently mentioned in the Australian Budget 2015. Organisation for Economic Co-operation and Development’s (OECD) involvement to concrete changes to avoid Base Erosion Profit Shifting (BEPS) has been mentioned. UK’s ‘Google tax’ and the ‘Double Irish Dutch sandwich’ tax evading structure is explained in an effort to elucidate the steps taken by Australian Government to encounter issues similar to them. Facts are stated with regard to the current Australian economy meshing these two new taxes into the existing taxation system. A conclusion is drawn concisely assessing the enforcement of ‘Digital GST’ and ‘Diverted Profit’ taxes and their probable effects on the economy. 1. The need for comprehensive tax reform One of the prime ways of generating economic revenue is to improve the tax capabilities. A good tax system promotes sustainable growth, provides key platform for trade and investments and strengthens the accountability of government to their citizens. The growing complexity in business and technological advances has made it difficult for the existing tax system to keep in pace...
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...Drawing on some real life examples of tax avoidance by Multinational Corporations (MNCs), what are the advantages and disadvantages of global MNCs’ using loopholes to pay less corporate tax? Word Count: 2074 Student ID: 1308346 Introduction: Taxation is the main source of income for most of the developed countries in the world. Multinational corporations with subsidiaries in different countries use loopholes in the laws to reduce their tax liabilities. Needham (2013) has defined tax avoidance as “seeking to minimize a tax bill without deliberate deception but contrary to the spirit of the law”. Firms evade to Tax Havens or use various methods such as transfer pricing and corporate debt-‐equity to avoid the payment of taxes. Palan (2002) defines tax havens as “countries that have enacted tax legislation especially designed to attract...
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...Insider's Recipes Master Edition Copyright© 2002 VJJE Publishing Co. Insider's Recipes Master Edition Table of Contents Introduction.........................................................................................................................................................1 101st Airborne Beer Cheese Soup ...................................................................................................................2 3 Musketeers Bars .............................................................................................................................................3 A&W Chili Dogs ...............................................................................................................................................4 A&W Onion Rings ............................................................................................................................................6 A1 Sauce .............................................................................................................................................................7 Almond Bark .....................................................................................................................................................8 Almond Joy Bars ...............................................................................................................................................9 Andouille Sausage ...........................................................................
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...Biscuit is a kind of crisp, dry bread product that, if leavened, is usually made with a chemical leavener. The exact meaning varies markedly in different parts of the world. The origin of the word "biscuit" is from Latin via Middle French and means "cooked twice," hence biscotti in Medieval Italian (similar to the German Zwieback, and still present in Dutch "beschuit"). In modern Italian usage the term biscotti is used to refer to any type of cookie or cracker. Some of the original biscuits were British naval hard tack; such hard tack was made in the United States through the 19th century. Throughout most of the world, the term biscuit still means a hard, crisp, brittle bread, except in the USA and Canada, where it now denotes a softer bread product baked only once. Biscuits derive its name from a French word meaning twice backed bread; Biscuits in general have a good shelf life, which is higher than all other snack items available in the market. A biscuit is a hard baked sweet or savory product like a small, flat cake, which in North America may be called a "cookie" or "cracker". The term biscuit also applies to sandwich-type biscuits, where a layer of 'cream' or icing is sandwiched between two biscuits. In the UK, "cookie" is usually only used in specific terms such as "chocolate chip cookie" or to refer to larger, softer American style cookies. Referring to the Sesame Street character the Cookie Monster, British author Chris Roberts quipped that he prefers the word "cookies"...
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...THE ORIGINS AND DEVELOPMENT OF THE ENGLISH LANGUAGE This page intentionally left blank THE ORIGINS AND DEVELOPMENT OF THE ENGLISH LANGUAGE SIXTH EDITION ± ± John Algeo ± ± ± ± ± Based on the original work of ± ± ± ± ± Thomas Pyles Australia • Brazil • Japan • Korea • Mexico • Singapore • Spain • United Kingdom • United States The Origins and Development of the English Language: Sixth Edition John Algeo Publisher: Michael Rosenberg Development Editor: Joan Flaherty Assistant Editor: Megan Garvey Editorial Assistant: Rebekah Matthews Senior Media Editor: Cara Douglass-Graff Marketing Manager: Christina Shea Marketing Communications Manager: Beth Rodio Content Project Manager: Corinna Dibble Senior Art Director: Cate Rickard Barr Production Technology Analyst: Jamie MacLachlan Senior Print Buyer: Betsy Donaghey Rights Acquisitions Manager Text: Tim Sisler Production Service: Pre-Press PMG Rights Acquisitions Manager Image: Mandy Groszko Cover Designer: Susan Shapiro Cover Image: Kobal Collection Art Archive collection Dagli Orti Prayer with illuminated border, from c. 1480 Flemish manuscript Book of Hours of Philippe de Conrault, The Art Archive/ Bodleian Library Oxford © 2010, 2005 Wadsworth, Cengage Learning ALL RIGHTS RESERVED. No part of this work covered by the copyright herein may be reproduced, transmitted, stored, or used in any form or by any means graphic, electronic, or mechanical, including...
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...vocabGCSE 09 Spanish Vocabulary book Version- Draft 1 GCSE Spanish Edexcel GCSE in Spanish Edexcel GCSE 2009 Spanish Vocabulary Book Edexcel are pleased to oprovide this free vocabulary book freely to support learners following the the Edexcel GCSE 2009 Specification in Spanish. Please note: the most up to date version of this document is available on the Edexcel website and a definitive list of core vocabulary is available in the Edexcel Specification. Introduction This bilingual glossary has been produced to support you in your language learning and to help you prepare for the Edexcel GCSE. It features a revised minimum core vocabulary foundation level vocabulary (this has been expanded from the original one in the specification) as well as higher level vocabulary. English meanings, genders and irregular word endings are given and the vocabulary is listed both alphabetically and under the following Edexcel headings: High Frequency Language Verbs Adjectives Colours Adverbs Numbers Quantities Connecting Words Time Expressions Times Days of the Week Months of the Year Question Words Countries Continents Nationalities Areas/Mountains/Cities/Rivers Acronyms and Abbreviations Social Conventions Prepositions Listening and Reading Topics Out and About - Visitor Information, Basic Weather, Local Amenities, Accommodation, Public Transport, Directions Customer Services and Transactions - Cafes and Restaurants, Shops, Dealing with Problems Personal Information - General...
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...------------------------------------------------- Top of Form Bottom of Form CORPORATE HISTORY 1995-1997 1995 * Larry Page and Sergey Brin meet at Stanford. (Larry, 22, a U Michigan grad, is considering the school; Sergey, 21, is assigned to show him around.) According to some accounts, they disagree about almost everything during this first meeting. 1996 * Larry and Sergey, now Stanford computer science grad students, begin collaborating on a search engine called BackRub. * BackRub operates on Stanford servers for more than a year—eventually taking up too much bandwidth to suit the university. 1997 * Larry and Sergey decide that the BackRub search engine needs a new name. After some brainstorming, they go with Google—a play on the word “googol,” a mathematical term for the number represented by the numeral 1 followed by 100 zeros. The use of the term reflects their mission to organize a seemingly infinite amount of information on the web. Back to top 1998 August * Sun co-founder Andy Bechtolsheim writes a check for $100,000 to an entity that doesn’t exist yet: a company called Google Inc. September * Google sets up workspace in Susan Wojcicki’s garage at 232 Santa Margarita, Menlo Park. * Google files for incorporation in California on September 4. Shortly thereafter, Larry and Sergey open a bank account in the newly-established company’s name and deposit Andy Bechtolsheim’s check. * Larry and Sergey hire Craig Silverstein...
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...ALSO BY JOHN GREEN Looking for Alaska An Abundance of Katherines Paper Towns Will Grayson, Will Grayson W ITH DAVID LEVITHAN DUTTON BOOKS | An imprint of Penguin Group (USA) Inc. DUTTON BOOKS A MEMBER O F PENGUIN GRO UP (USA ) INC . Published by the Penguin Group | Penguin Group (USA ) Inc., 375 Hudson Street, New York, New York 10014, U.S.A . | Penguin Group (C anada), 90 Eglinton A v enue East, Suite 700, Toronto, O ntario M4P 2Y3, C anada (a div ision of Pearson Penguin C anada Inc.) | Penguin Books Ltd, 80 Strand, London WC 2R 0RL, England | Penguin Ireland, 25 St Stephen’s Green, Dublin 2, Ireland (a div ision of Penguin Books Ltd) | Penguin Group (A ustralia), 250 C amberw ell Road, C amberw ell, V ictoria 3124, A ustralia (a div ision of Pearson A ustralia Group Pty Ltd) | Penguin Books India Pv t Ltd, 11 C ommunity C entre, Panchsheel Park, New Delhi - 110 017, India | Penguin Group (NZ), 67 A pollo Driv e, Rosedale, A uckland 0632, New Zealand (a div ision of Pearson New Zealand Ltd) | Penguin Books (South A frica) (Pty ) Ltd, 24 Sturdee A v enue, Rosebank, Johannesburg 2196, South A frica | Penguin Books Ltd, Registered O ffices: 80 Strand, London WC 2R 0RL, England This book is a w ork of fiction. Names, characters, places, and incidents are either the product of the author’s imagination or are used fictitiously , and any resemblance to actual persons, liv ing or dead, business establishments, ev ents, or locales is entirely coincidental. C opy right ©...
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...ALSO BY JOHN GREEN Looking for Alaska An Abundance of Katherines Paper Towns Will Grayson, Will Grayson W ITH DAVID LEVITHAN DUTTON BOOKS | An imprint of Penguin Group (USA) Inc. DUTTON BOOKS A MEMBER O F PENGUIN GRO UP (USA ) INC . Published by the Penguin Group | Penguin Group (USA ) Inc., 375 Hudson Street, New York, New York 10014, U.S.A . | Penguin Group (C anada), 90 Eglinton A v enue East, Suite 700, Toronto, O ntario M4P 2Y3, C anada (a div ision of Pearson Penguin C anada Inc.) | Penguin Books Ltd, 80 Strand, London WC 2R 0RL, England | Penguin Ireland, 25 St Stephen’s Green, Dublin 2, Ireland (a div ision of Penguin Books Ltd) | Penguin Group (A ustralia), 250 C amberw ell Road, C amberw ell, V ictoria 3124, A ustralia (a div ision of Pearson A ustralia Group Pty Ltd) | Penguin Books India Pv t Ltd, 11 C ommunity C entre, Panchsheel Park, New Delhi - 110 017, India | Penguin Group (NZ), 67 A pollo Driv e, Rosedale, A uckland 0632, New Zealand (a div ision of Pearson New Zealand Ltd) | Penguin Books (South A frica) (Pty ) Ltd, 24 Sturdee A v enue, Rosebank, Johannesburg 2196, South A frica | Penguin Books Ltd, Registered O ffices: 80 Strand, London WC 2R 0RL, England This book is a w ork of fiction. Names, characters, places, and incidents are either the product of the author’s imagination or are used fictitiously , and any resemblance to actual persons, liv ing or dead, business establishments, ev ents, or locales is entirely coincidental. C opy right ©...
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...Downloaded by [University of Ottawa] at 14:44 24 March 2014 Football, Violence and Social Identity Downloaded by [University of Ottawa] at 14:44 24 March 2014 As the 1994 World Cup competition in the USA again demonstrates, football is one of the most popular participant and spectator sports around the world. The fortunes of teams can have great significance for the communities they represent at both local and national levels. Social and cultural analysts have only recently started to investigate the wide variety of customs, values and social patterns that surround the game in different societies. This volume contributes to the widening focus of research by presenting new data and explanations of football-related violence. Episodes of violence associated with football are relatively infrequent, but the occasional violent events which attract great media attention have their roots in the rituals of the matches, the loyalties and identities of players and crowds and the wider cultures and politics of the host societies. This book provides a unique cross-national examination of patterns of order and conflict surrounding football matches from this perspective with examples provided by expert contributors from Scotland, England, Norway, the Netherlands, Italy, Argentina and the USA. This book will be of interest to an international readership of informed soccer and sport enthusiasts and students of sport, leisure, society, deviance and culture. Richard Giulianotti, Norman...
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...Simply defined, linguistics is the scientific study of language. Though various types of language studies (including grammar and rhetoric) can be traced back over 2,500 years, the era of modern linguistics is barely two centuries old. Kicked off by the late-18th-century discovery that many European and Asian languages descended from a common tongue (Proto-Indo-European), modern linguistics was reshaped, first, by Ferdinand de Saussure (1857-1913) and more recently by Noam Chomsky (born 1928). The systematic study of the nature, structure, and variation of language. Major subfields of linguistics include phonetics, phonology, morphology, syntax, semantics, pragmatics, and discourse analysis. The founder of modern structural linguistics was Ferdinand de Saussure (1857-1913), whose most influential work, Course in General Linguistics, was edited by his students and published in 1916. Source: An Introduction to Language by Victoria Fromkin and Robert Rodman, 6th Ed.) Part One: Introduction to Linguistics Every human knows at least one language, spoken or signed. Linguistics is the science of language, including the sounds, words, and grammar rules. Words in languages are finite, but sentences are not. It is this creative aspect of human language that sets it apart from animal languages, which are essentially responses to stimuli. The rules of a language, also called grammar, are learned as one acquires a language. These rules include phonology, the sound system, morphology, the...
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...Kelly | McGowen | Williams C en ga Australia • Brazil • Japan • Korea • Mexico • Singapore • Spain • United Kingdom • United States ge Le ar ni ng BUSN BUSN BUSN 6, 6th Edition Kelly | McGowen | Williams © 2014 Cengage Learning. All rights reserved. Senior Project Development Manager: Linda deStefano Market Development Manager: Heather Kramer Senior Production/Manufacturing Manager: Donna M. Brown Production Editorial Manager: Kim Fry Sr. Rights Acquisition Account Manager: Todd Osborne en C Printed in the United States of America ga ge Le Compilation © 2013 Cengage Learning ISBN-13: 978-1-285-88034-1 ISBN-10: 1-285-88034-X Cengage Learning 5191 Natorp Boulevard Mason, Ohio 45040 USA ALL RIGHTS RESERVED. No part of this work covered by the copyright herein LL RIGHT th repro reprodu ted, s may be reproduced, transmitted, stored or used in any form or by any means electro graphic, electronic, or mechanical, including but not limited to photocopying, scann di recording, scanning, digitizing, taping, Web distribution, information networks, a or information storage and retrieval systems, except as permitted under o t Section 107 or 108 of the 1976 United States Copyright Act, without the prior writ written permission of the publisher. pro For product information and technology assistance, contact us at Cen Cengage Learning Customer & Sales Support, 1-800-354-9706 For permission to use material from this text or product, submit...
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