Double Dutch sandwich

The “double Dutch sandwich” is a complex tax technique that is used by some large multinational companies to minimize their tax bill by exploiting the tax laws of the Netherlands.

The double Dutch sandwich involves the use of two intermediary Dutch companies to transfer funds from a subsidiary located in one country to another subsidiary located in another country. This technique helps reduce taxes paid on profits earned by these subsidiaries, as Dutch tax laws provide tax benefits such as tax credits for dividends and tax deductions for interest.

The first “sandwich” consists of a foreign subsidiary making payments to a Dutch intermediary company, which then transfers these payments to another foreign subsidiary. The second “sandwich” is formed by the second foreign subsidiary, which is owned by a second Dutch intermediary company, which in turn transfers payments to a third foreign subsidiary.

Using this technique, multinational companies can transfer funds from one country to another without paying as much tax on the profits made by their subsidiaries, because these payments are deducted from taxable profits in the different countries.

However, it is important to note that the use of the double Dutch sandwich is increasingly criticized by governments and international organizations, who consider this technique to be abusive and harmful to tax fairness. The Netherlands recently adopted new rules to limit the use of this technique.

Double Maltese

The “double Maltese” is a complex tax technique used by some multinational companies to reduce their tax bill. It is similar to the “double Dutch sandwich” but with Malta instead of the Netherlands.

Dual Maltese involves the use of two intermediary Maltese companies to transfer funds from one subsidiary located in one country to another subsidiary located in another country. This technique reduces the taxes paid on the profits made by these subsidiaries, as Maltese tax laws provide tax benefits such as tax credits for dividends and tax deductions for interest.

The first “Maltese” consists of a foreign subsidiary which makes payments to a Maltese intermediary company, which then transfers these payments to another foreign subsidiary. The second “Maltese” is formed by the second foreign subsidiary, which is owned by a second Maltese intermediary company, which in turn transfers the payments to a third foreign subsidiary.

Using this technique, multinational corporations can transfer funds from one country to another without paying as much tax on the profits made by their subsidiaries, as these payments are deducted from the taxable profits in the different countries.

However, it is important to note that the use of this technique is increasingly controversial and criticized by governments and international organizations, who consider that it can be considered an abusive tax practice and harmful to tax fairness. International and national tax rules are changing to limit the use of these techniques.

Tax “ruling” in Switzerland

A tax “ruling” in Switzerland is an advance ruling in tax matters, which allows taxpayers to clarify their tax situation by obtaining advance confirmation from the tax authorities on the interpretation of tax law in a given situation.

The taxpayer submits a ruling request to the tax administration detailing the facts and circumstances of his tax situation. The tax administration then analyzes the request and provides a written response confirming the position of the tax administration on the question raised.

The ruling can be binding or non-binding. In the case of a binding ruling, the tax administration undertakes to respect the position confirmed in the ruling, provided that the facts and circumstances of the tax situation do not change. In the case of a non-binding ruling, the tax administration simply provides its interpretation of the tax law, but is not bound by this interpretation.

The use of tax rulings is common in Switzerland, in particular for large multinational companies seeking to obtain advance confirmations from the tax authorities on the tax consequences of their operations. However, the use of these tax rulings is increasingly scrutinized by governments and international organizations, which consider that this can be considered an abusive tax practice and harmful to tax fairness.

Advantages of UK companies

There are several advantages to setting up a company in London, which is one of the most important financial centers in the world. Here are some potential benefits:

An attractive tax regime: London offers a relatively low corporate tax rate compared to other European financial centres, which can be an advantage for businesses.

Access to a wide range of talent: London is a cosmopolitan city that attracts many highly qualified and talented professionals, which can be beneficial for companies looking to recruit quality staff.

A stable regulatory framework: The UK has a stable and respected regulatory framework, which provides an environment conducive to doing business.

Access to international financial markets: London is one of the most important financial centers in the world, offering access to international financial markets and to potential investors.

A startup-friendly environment: London is known to be a very startup-friendly city, with a large number of incubators and accelerators for young companies.

The English language: London is an English-speaking city, which can make doing business easier for companies operating in English-speaking countries or for companies looking to expand their presence in English-speaking markets.

However, it is important to note that the benefits of setting up a company in London may vary depending on each company’s individual situation and that it is essential to fully understand the applicable tax and business regulations before making a decision. .