Editing Corporate haven (section)

===Tools===

Tax academics identify that extracting untaxed profits from higher-tax jurisdictions requires several components:<ref name="dut2">{{cite news|url=https://www.theguardian.com/business/2011/oct/19/tax-avoidance-in-netherlands-becomes-focus-of-campaigners|title=Dutch masters of tax avoidance|newspaper=The Guardian|date=19 October 2011|access-date=14 May 2018|archive-url=https://web.archive.org/web/20180515080658/https://www.theguardian.com/business/2011/oct/19/tax-avoidance-in-netherlands-becomes-focus-of-campaigners|archive-date=15 May 2018|url-status=live|df=dmy-all}}</ref><ref name="zew">{{cite web|url=http://ftp.zew.de/pub/zew-docs/dp/dp13078.pdf|title=Profit Shifting and "Aggressive" Tax Planning by Multinational Firms|page=3|publisher=Centre for European Economic Research (ZEW)|date=October 2013|access-date=2018-05-18|archive-url=https://web.archive.org/web/20170811020522/http://ftp.zew.de/pub/zew-docs/dp/dp13078.pdf|archive-date=2017-08-11|url-status=dead}}</ref>
{{ordered list|type=lower-roman
|{{slink||IP-based BEPS tools}}, which enable the profits to be extracted via the cross-border charge-out of group IP (known as "intergroup IP charging"); and/or
|{{slink||Debt-based BEPS tools}}, which enable the profits to be extracted via the cross-border charge-out artificially high interest (known as "earnings stripping"); and/or
|{{slink||TP-based BEPS tools}}, which enable profits to be extracted by claiming that a ''process'' performed on the product in the jurisdiction justifies a large increase in the [[Transfer pricing|transfer price]] ("TP") at which the finished product is charged-out at, in the jurisdiction, to higher-tax jurisdictions (known as [[contract manufacturing]]); and
|Bilateral tax treaties with the corporate tax haven, which accept these BEPS tools as deductible against tax in the higher-tax jurisdictions.
}}
Once the untaxed funds are rerouted back to the corporate tax haven, additional BEPS tools shield against paying taxes in the haven.  It is important these BEPS tools are complex and obtuse so that the higher-tax jurisdictions do not feel the corporate haven is a traditional tax haven (or they will suspend the bilateral tax treaties).  These complex BEPS tools often have interesting labels:<ref name="zew"/><ref name="caid">{{cite web|url=https://www.christianaid.ie/sites/default/files/2018-02/impossible-structures-tax-report.pdf|title='Impossible' structures: tax outcomes overlooked by the 2015 tax Spillover analysis|publisher=Christian Aid|date=2017|access-date=2018-05-21|archive-url=https://web.archive.org/web/20180322020723/https://www.christianaid.ie/sites/default/files/2018-02/impossible-structures-tax-report.pdf|archive-date=2018-03-22|url-status=dead}}</ref>
{{ordered list|type=lower-roman
|[[Royalty payment]] BEPS tools to reroute the funds to a low tax jurisdiction (i.e. [[double Irish]] and [[Double Irish arrangement#Replacement by Single Malt|single malt]] in Ireland or [[dutch sandwich]] in the Netherlands); or
|[[Capital allowance]] BEPS tools that allow IP assets to be written off against taxes in the jurisdiction (i.e. Apple's 2015 [[Double Irish arrangement#Backstop of capital allowances|capital allowances for intangibles]] tool in [[leprechaun economics]]); or
|Lower IP-sourced income tax regimes, offering explicitly lower ETRs against charging out of cross-border group IP (i.e. the U.K. [[patent box]], or the Irish [[Corporation tax in the Republic of Ireland#Knowledge Development Box|knowledge box]]); or
|Beneficial treatment of interest income (from {{slink||Debt-based BEPS tools}}), enabling it to be treated as non-taxable (i.e. the Dutch "double dipping" interest regime<ref name="dut10">{{cite news|url=https://www.theguardian.com/politics/2010/dec/10/taxandspending-taxavoidance|title=Dutch Double Dips and Dutch Sandwiches|newspaper=The Guardian|date=10 December 2010|access-date=25 May 2018|archive-url=https://web.archive.org/web/20180526041648/https://www.theguardian.com/politics/2010/dec/10/taxandspending-taxavoidance|archive-date=26 May 2018|url-status=live|df=dmy-all}}</ref>); or
|Restructuring the income into a [[securitisation]] vehicle (by owning the IP, or other asset, with debt), and then "washing" the debt by "back-to-backing" with a Eurobond (i.e. [[Irish Section 110 Special Purpose Vehicle (SPV)#Evolution|Orphaned Super-QIAIF]]).  
}}