4strategies that American companies use 2reduce their taxes (Video 3:35) http://video.nytimes.com/video/2011/06/19/business/100000000870844/inside-the-accountants-playbook.html
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The Netherlands to EU: Hands off our pensions
“After the effective nationalisation of the private pension schemes in Hungary and Poland last week, only a handful of countries have large pension reserves. Think of the UK, the Netherlands, Sweden and Denmark. [...] The European commission should first ask itself the question: whose money is in the pension funds? These are national funds, paid for by employers and employees. It is not government money. It is not European money. This in itself is more than sufficient reason for the commission not to extend its power to national pension systems. Only for cross-border workers (a tracking service) can an exception be made. [...]
The temptations in Europe are very large. The Dutch pension sector alone controls more than €750bn ($991bn), about as much as is available in the Eurocrisis fund, if the maximum can ever be used. But this money cannot and will not be brought under European control. The Dutch parliament unanimously approved my recommendation to that effect.
I count on support from fellow nations and MPs to rely far less on European pensions and money. ”
http://www.cda.nl/Omtzigt/Actueel/Nieuws/2010/12/49/Hands_off_our_pensions.aspx
Cf.: http://euractiv.com/en/euro-finance/poland-strikes-pension-deal-with-eu-news-500531
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Inside the Rolling Stones Inc.
“[...] in many respects the Rolling Stones are like any other large business. They are global, they pay taxes (grudgingly), and they litigate. The band has a P&L and budgets, and accountants, and lawyers, and bankers, and investments, and software, and hardware. “They know what they’re doing,” says Barry Diller, a Jagger confidant. “That’s what separates them from any other band.” [...]
Connected to the Stones partnership and Prince Rupert is a group of companies that include Promotour, Promopub, Promotone, and Musidor, each dedicated to a particular aspect of the business. This family of companies is based in the Netherlands, which has tax advantages for foreign bands. When the group isn’t touring, these companies employ only a few dozen employees. At the high-water mark of a tour, on the night the band is playing, say, Giants Stadium, the Stones may employ more than 350. Backstage the enterprise resembles a flourishing startup, with dozens of fast-moving junior employees in black T-shirts running around to make sure the IPO, er, the show, gets off without a hitch. It looks crazy, but it works. Perhaps Keith sums it up best: “With our business, who really knows what’s what. You go and look at Lake Superior, and you say, ‘Look at all that water, and that’s just the top!’” [...]
The Stones are famously tax-averse. I broach the subject with Keith in Camp X-Ray, as he calls his backstage lair. There is incense in the air and Ronnie Wood drifts in and out–it is, in other words, a perfect venue for such a discussion. “The whole business thing is predicated a lot on the tax laws,” says Keith, Marlboro in one hand, vodka and juice in the other. “It’s why we rehearse in Canada and not in the U.S. A lot of our astute moves have been basically keeping up with tax laws, where to go, where not to put it. Whether to sit on it or not. We left England because we’d be paying 98 cents on the dollar. We left, and they lost out. No taxes at all. I don’t want to screw anybody out of anything, least of all the governments that I work with. We put 30% in holding until we sort it out.” No wonder Keith chooses to live not in London, or even New York City, but in Weston, Conn.”
http://money.cnn.com/magazines/fortune/fortune_archive/2002/09/30/329302/index.htm
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“Google Inc. cut its taxes by $3.1 billion in the last three years using a technique that moves most of its foreign profits through Ireland and the Netherlands to Bermuda.
Google’s income shifting — involving strategies known to lawyers as the “Double Irish” and the “Dutch Sandwich” — helped reduce its overseas tax rate to 2.4 percent, the lowest of the top five U.S. technology companies by market capitalization [...]
Google, the third-largest U.S. technology company by market capitalization, hasn’t been accused of breaking tax laws. “Google’s practices are very similar to those at countless other global companies operating across a wide range of industries,” [...]
The tactics of Google and Facebook depend on “transfer pricing,” paper transactions among corporate subsidiaries that allow for allocating income to tax havens while attributing expenses to higher-tax countries. Such income shifting costs the U.S. government as much as $60 billion in annual revenue [...]
Google is “flying a banner of doing no evil, and then they’re perpetrating evil under our noses,” said Abraham J. Briloff, a professor emeritus of accounting at Baruch College in New York who has examined Google’s tax disclosures.
“Who is it that paid for the underlying concept on which they built these billions of dollars of revenues?” Briloff said. “It was paid for by the United States citizenry. [...]
In February, the Obama administration proposed measures to curb shifting profits offshore, part of a package intended to raise $12 billion a year over the coming decade. While the key proposals largely haven’t advanced in Congress, the IRS said in April it would devote additional agents and lawyers to focus on five large transfer pricing arrangements.
Income shifting commonly begins when companies like Google sell or license the foreign rights to intellectual property developed in the U.S. to a subsidiary in a low-tax country. That means foreign profits based on the technology get attributed to the offshore unit, not the parent. Under U.S. tax rules, subsidiaries must pay “arm’s length” prices for the rights — or the amount an unrelated company would.
Because the payments contribute to taxable income, the parent company has an incentive to set them as low as possible. Cutting the foreign subsidiary’s expenses effectively shifts profits overseas.
After three years of negotiations, Google received approval from the IRS in 2006 for its transfer pricing arrangement, according to filings with the Securities and Exchange Commission.
The IRS gave its consent in a secret pact known as an advanced pricing agreement. Google wouldn’t discuss the price set under the arrangement, which licensed the rights to its search and advertising technology and other intangible property for Europe, the Middle East and Africa to a unit called Google Ireland Holdings, according to a person familiar with the matter.
That licensee in turn owns Google Ireland Limited, which employs almost 2,000 people in a silvery glass office building in central Dublin, a block from the city’s Grand Canal. The Dublin subsidiary sells advertising globally and was credited by Google with 88 percent of its $12.5 billion in non-U.S. sales in 2009.
Allocating the revenue to Ireland helps Google avoid income taxes in the U.S., where most of its technology was developed. The arrangement also reduces the company’s liabilities in relatively high-tax European countries where many of its customers are located.
The profits don’t stay with the Dublin subsidiary, which reported pretax income of less than 1 percent of sales in 2008, according to Irish records. That’s largely because it paid $5.4 billion in royalties to Google Ireland Holdings, which has its “effective centre of management” in Bermuda, according to company filings. [...]
Tax planners call such an arrangement a Double Irish because it relies on two Irish companies. One pays royalties to use intellectual property, generating expenses that reduce Irish taxable income. The second collects the royalties in a tax haven like Bermuda, avoiding Irish taxes.
To steer clear of an Irish withholding tax, payments from Google’s Dublin unit don’t go directly to Bermuda. A brief detour to the Netherlands avoids that liability, because Irish tax law exempts certain royalties to companies in other EU- member nations. The fees first go to a Dutch unit, Google Netherlands Holdings B.V., which pays out about 99.8 percent of what it collects to the Bermuda entity, company filings show. The Amsterdam-based subsidiary lists no employees. [...]
Microsoft, based in Redmond, Washington, has also used a Double Irish structure, according to company filings overseas. Forest Laboratories Inc., maker of the antidepressant Lexapro, does as well [...]
While the administration “remains concerned” about potential abuses, officials decided “to defer consideration of how to reform those rules until they can be studied more broadly,” said Sandra Salstrom, a Treasury spokeswoman. The White House still proposes to tax excessive profits of offshore subsidiaries as a curb on income shifting, she said.
The rules for transfer pricing should be replaced with a system that allocates profits among countries the way most U.S. states with a corporate income tax do — based on such aspects as sales or number of employees in each jurisdiction, said Reuven S. Avi-Yonah, director of the international tax program at the University of Michigan Law School. [...]”
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http://www.irishtimes.com/newspaper/finance/2010/1025/1224281951684.html