[seanhunter]

Yeah there's the so called "Dutch Sandwich"[1] which is a well-known tax "planning" methodology that corporates use with the so called "Double Irish" being another one. There's also a slightly less-well known one involving Mauritius and India. They're all ways of moving profits between companies in order to exploit tax treaties that countries put in place. In the case of the Dutch sandwich I think the Netherlands has a treaty with the Netherlands Antilles or something so people have a company in the Netherlands which then shifts things off-shore to the Antilles and avoids tax that way.

It's nonsense of course. Companies should (in my opinion) shoulder their fair share of tax because otherwise that burden falls disproportionately on individual income tax.

[1] https://en.wikipedia.org/wiki/Dutch_Sandwich

[s_dev]

Your information is outdated -- Double Irish is no longer applicable according to your own source since 2010.

[yunohn]

No, it’s much more complicated than that. If you scroll a bit further:

> After pressure from the EU,[22] the Double Irish BEPS tool was closed to new users in 2015,[citation needed] however, new Irish BEPS tools were created to replace it:[23][24]

Not only do the original evaders get to continue doing it, they’ve also found new loopholes already.

[seanhunter]

Right. Also I wasn't trying (nor am I equipped) to give some kind of current guide to tax dodging. I was explaining the basic sort of thing people do. The specifics change all the time because there is a sort of whack-a-mole that tax authorities try to play to get people to pay and people pay ever more and more inflated fees to various accountants and tax "planning" experts for ever more byzantine and artificial schemes of one kind or another.

My own experience with tax experts has left me pretty jaded about tax advice. It seems to me that often these companies have maybe 1 dude who actually understands tax and an army of people with powerpoint going out selling the "solution". I had a complex tax situation when setting up a business in the UK and US and got tax advice from one of the big four firms not to dodge tax but to make sure I understood the US system correctly and was paying everything I should. I paid so much tax that I got investigated in both the UK and US because they thought there must be some sort of fiddle because I seemed to be paying way more than I sholud be (this was what I told the accountants). I ended up getting rebates from the IRS and from the UK HMRC after the investigations but it took a couple of years to get it all sorted out.

[Muromec]

It's like eruv. The loophole was planted there for us mortals to find and use it

[gamblor956]

None of these tax "planning" schemes are available anymore.

Moreover, tax authorities have increasingly taken the position that the use of these planning methods constitutes tax evasion. The Dutch Sandwich and Double Irish were grandfathered in (meaning, not treated as criminal tax evasion) but a company utilizing similar schemes today would ultimately result in one or more of their executives spending time in jail.

Critically, most of tax law is actually regulation that implements statutes. Tax planning schemes that satisfy the technical letter of regulations but which violate the plain intent of the written statute can, and have, been deemed illegal years or even decades later (see, for example, the Bermudan tax loss harvesting scheme), and this has repeatedly passed constitutional muster.

[tiahura]

What’s the rationale for double taxing corporate profits vs other types?

[seanhunter]

No rationale for that, but likewise no rational reason that corporates sholud be able to use multinational structures to completely avoid tax, which is what these planning structures are all about. Typically there are inter-company transfer pricing arrangements that mean that the companies in the taxed jurisdictions pay fees to each other so their profits are minimised and as much profit as possible is expatriated to low- or no-tax jurisdictions.