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“Double Irish”, tax leverage and structuring of IP companies

Structuring a company is a critical component of any business, whether startup or public. This is where the value for the company as well as shareholders gets captured and unlocked overtime.

I saw a good article on the Double Irish and wanted to share this. It’s just fair to note that whatever is done is done in the best interests and with leverage of what is legal and compliant.

The “Double Irish” scheme takes advantage of a loophole in Irish law, which enables companies to be registered in Ireland without being tax resident in the country. This allows Google to hold its IP in an Irish company that is tax resident in Bermuda, which has a zero rate of corporate tax. LinkedIn, the world’s biggest professional-networking website, holds its IP in an Irish company that is tax resident in the Isle of Man, which also has zero rate of corporate tax.

Tax_Structuring_Ireland September 12, 2013 3:58 pm

Adobe shows its creativity with Ireland tax base

By Jamie Smyth in Dublin

This article from the FT which I just saw coincidentally during an equity structuring meeting taking a break and wanted to share this. It does not reflect negatively on any specific company, rather just the creativity of leveraging the ability to structure a company’s capital and equity as per international frameworks.

As far as IP companies the more the ability to deploy capital to further create new IP that creates jobs is a greater ROI for governments and societies, rather than just one rule for all which is a short term yield and a long term loss.  Job creation is the engine of any economy and tax leverage on these industries are critical. Just look at how an Indian software services industry reached a $100B scale, tax structuring of no corporate tax for exports of services played a critical role. Now that is a case in point.

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