1. What features of the interaction between 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 that allowed a company based abroad to be registered as an Irish company. For example, a company based in a tax haven such as Bermuda can be an “Irish” company and subsequently lead to firms legally avoiding paying billions of dollars in corporation tax.
In 1988, the UK introduced laws to prevent the use of UK incorporated but non-tax resident