The Double Irish and Dutch Sandwich tax strategies: Could a general anti-avoidance rule counteract the problems caused by the utilisation of these structures?

<p>This paper analyses the Double Irish and Dutch Sandwich tax structures used by large multinational enterprises. These structures enable companies to shift significant profits to offshore tax havens through the use of wholly owned subsidiaries in Ireland and the Netherlands. Application of the New Zealand General Anti-Avoidance rule in s BG 1 of the Income Tax Act 2007 reveals that any attempt to counteract these structures would be highly fact dependent. The paper concludes that it would be possible to apply the rule, but that there would be practical difficulties in relation to enforceability of the Commissioner’s ruling. A similar result was reached when applying the United States General Anti-Avoidance rule. The attempted application of the General Anti-Avoidance rules reveals a fundamental flaw in the income tax system. That is, the inability of the current system to regulate and control intangible resources and technology based transactions.</p>

The Double Irish and Dutch Sandwich tax strategies: Could a general anti-avoidance rule counteract the problems caused by the utilisation of these structures?

<p>This paper analyses the Double Irish and Dutch Sandwich tax structures used by large multinational enterprises. These structures enable companies to shift significant profits to offshore tax havens through the use of wholly owned subsidiaries in Ireland and the Netherlands. Application of the New Zealand General Anti-Avoidance rule in s BG 1 of the Income Tax Act 2007 reveals that any attempt to counteract these structures would be highly fact dependent. The paper concludes that it would be possible to apply the rule, but that there would be practical difficulties in relation to enforceability of the Commissioner’s ruling. A similar result was reached when applying the United States General Anti-Avoidance rule. The attempted application of the General Anti-Avoidance rules reveals a fundamental flaw in the income tax system. That is, the inability of the current system to regulate and control intangible resources and technology based transactions.</p>

Body as Revolt: The Myth of Nangeli, the Woman who Covered her Breast

The paper deals with the myth of Nangeli, a Dalit woman who stood against the improper tax structures that prevailed in the Kingdom of Travancore in Kerala. The paper also talks about the question of gender equality and the way women claim for equal opportunity with men by going topfree. The paper discusses the portrayal of the Nangelimyth in various art forms like paintings, fiction, film and graphic novels.

Progress on EU-Swiss deal remains a distance away

Significance Political divisions in Switzerland have put the deal on hold. By threatening some of Switzerland's existing privileges, the Commission is seeking to increase the pressure for the signature and ratification of a deal agreed in late 2018. Impacts The experience of negotiating Brexit will make the EU less willing to give concessions to third countries over single market access. Switzerland’s export industries and financial services firms would be worst affected if the IFA collapses. The Swiss economy would be one of the worst-affected in Europe from global reforms to corporate tax structures.

Lay Elites under Arab Rule

This chapter makes the case that the seventh century did not see the immediate disappearance of the landowning elite in the Levant. It discusses how the melting away of the Roman state created opportunities for the aristocracy to enrich itself. It also refers to the tax structures of the new state that forced the aristocrats to find new avenues to power and influence, such as state administration or church hierarchy. The chapter uses letters and saints' lives to chart how many aristocracies benefited from the collapse of the Roman and Sasanian empires before the caliphs started to reassert their authority and demand higher taxes in the eighth century. It describes how non-Muslim, landed aristocrats persisted in many areas and Muslim patrons who protected the elites' interests.