Editing Corporate haven (section)

===Dutch "Double Dip"===
[[Image:JoopWijn.jpg|thumb|right|'''Ex. Dutch Minister [[Joop Wijn]]''' credited with introducing the [[Dutch Sandwich]] IP-based BEPS tool (which is often used with the [[Double Irish]] BEPS tool), and the "Dutch Double Dip" Debt-based BEPS tool]]
While the focus of corporate tax havens continues to be on developing new IP-based BEPS tools (such as OECD-compliant knowledge/patent boxes), Ireland has developed new BEPS tools leveraging traditional [[securitisation]] SPVs, called [[Irish Section 110 Special Purpose Vehicle (SPV)|Section 110 SPVs]].  Use of intercompany loans and loan interest was one of the original BEPS tools and was used in many of the early U.S. corporate [[tax inversion]]s (was known as [[Corporate inversion#Mechanics|"earnings-stripping"]]).<ref>{{cite news|url=https://www.bloomberg.com/quicktake/tax-inversion|title=Bloomberg Special TAX INVERSION|newspaper=Bloomberg.com|publisher=Bloomberg|date=2 May 2017|access-date=13 May 2018|archive-url=https://web.archive.org/web/20180413010306/https://www.bloomberg.com/quicktake/tax-inversion|archive-date=13 April 2018|url-status=live|df=dmy-all}}</ref>

The Netherlands has been a leader in this area, using specifically worded legislation to enable IP-light companies further amplify "earnings-stripping".  This is used by mining and resource extraction companies, who have little or no IP, but who use high levels of leverage and asset financing.<ref name="neth">{{cite web|url=https://www.oxfam.org/sites/www.oxfam.org/files/file_attachments/netherlands-taxhaven.pdf|title=The Netherlands: a tax haven continuing its contribution to the corporate tax race to the bottom (translated)|publisher=Oxfam Novib|date=May 2016|access-date=2018-05-23|archive-url=https://web.archive.org/web/20180623212542/https://www.oxfam.org/sites/www.oxfam.org/files/file_attachments/netherlands-taxhaven.pdf|archive-date=2018-06-23|url-status=dead}}</ref><ref name="dut2"/>  Dutch tax law enables IP-light companies to "overcharge" their subsidiaries for asset financing (i.e. reroute all untaxed profits back to the Netherlands), which is treated as tax-free in the Netherlands.  The technique of getting full tax-relief for an artificially high-interest rate in a foreign subsidiary, while getting additional tax relief on this income back home in the Netherlands, became known by the term, "double dipping".<ref name="dut10"/><ref>{{cite web|url=https://home.kpmg.com/content/dam/kpmg/pdf/2014/05/netherlands-2014.pdf|title=The Netherlands: Taxation of Cross-Border Mergers|publisher=KPMG|date=April 2014|access-date=2018-05-25|archive-url=https://web.archive.org/web/20151210083939/https://home.kpmg.com/content/dam/kpmg/pdf/2014/05/netherlands-2014.pdf|archive-date=2015-12-10|url-status=live}}</ref>   As with the [[Dutch sandwich]], ex. Dutch Minister [[Joop Wijn]] is credited as its creator.

{{quote|In 2006 he [ [[Joop Wijn]] ] abolished another provision meant to prevent abuse, this one pertaining to hybrid loans. Some revenue services classify those as loans, while others classify those as capital, so some qualify payments as interest, others as profits. This means that if a Dutch company provides such a hybrid [and very high interest] loan to a foreign company, the foreign company could use the payments as a tax deduction, while the Dutch company can classify it as profit from capital, which is exempt from taxes in the Netherlands [called "double dipping"]. This way no taxes are paid in either country.|source=[[Oxfam]]/''[[De Correspondent]]'', "How the Netherlands became a Tax Haven", 31 May 2017.<ref name="oxf"/><ref name="dec"/>}}