Segundo o texto, a principal finalidade do Double Irish era
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Ano: 2026
Banca:
FCC
Órgão:
SEFAZ-SP
Prova:
FCC - 2026 - SEFAZ-SP - Auditor Fiscal da Receita Estadual - AFRE - Tecnologia da Informação e Comunicação - Conhecimentos Gerais (P1) |
Q3916803
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Big Techs
When tax bills are in the millions or even billions, some individuals will go to any lengths to avoid paying up
RS, HMRC, FTS or CRA: whatever you like to call him, there's no hiding from the taxman. No individual or institution is immune from
the annual tax deadline, although many aim to reduce what they pay as much as possible through regulatory loopholes and profit
redistribution schemes.
When that tips over into illegal territory, though, it becomes a major problem. The International Monetary Fund (IMF) estimates that
over $600bn is lost every year due to tax avoidance, with the US, China and Japan named as the greatest culprits.
Multinational technology companies including Google, Apple and Amazon have been slapped with multiple allegations in recent years
regarding non-payment of taxes in Europe. In 2016, Apple was ordered to pay $15.4bn in back taxes to Ireland after it was revealed
that the company paid just one percent tax on its European profits in 2003, down to 0.005 percent in 2014. That same year Google was
accused of using two regulatory loopholes, nicknamed the 'double Irish', allowing it to pay just six percent corporation tax rather than
the required 19.3 percent.
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States
multinationals since the late 1980s to avoid corporate taxation on non-US profits. (The US was one of a small number of countries that
did not use a "territorial" tax system, and taxed corporations on all profits, no matter whether the profit was made outside the US or not,
in contrast to "territorial" tax systems which tax only profits made within that country.) It was the largest tax avoidance tool in history. By
2010, it was shielding US$100 billion annually in US multinational foreign profits from taxation, and was the main tool by which US
multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018.
Despite US knowledge of the Double Irish for a decade, it was the European Commission that in October 2014 forced Ireland to close
the scheme, starting in January 2015. However, users of existing schemes, such as Apple, Google, Facebook and Pfizer, were given
until January 2020 to close them.
At the announcement of the closure, it was known that multinationals had replacement BEPS tools in Ireland, the Single Malt (2014),
and Capital Allowances for Intangible Assets (CAIA) (2009):
-Single malt is almost identical to the Double Irish, and was identified with Microsoft (Linkedln), and Allergan in 2017;
-CAIA can provide up to twice the tax shield of Single Malt, or Double Irish, and was identified with Apple in the 2015 leprechaun
economics affair, i.e., a huge statistical distortion in Ireland's GDP caused by Apple's tax restructuring. The company transferred
intangible assets to its Irish subsidiary, which artificially inflated the country's GDP by more than 26.3% in a single year (later
revised to 24.6%), an absurd leap for a relatively small economy. This growth did not reflect real production, but rather Apple's tax
inversion of about US$ 300 billion of its intangible assets (mainly intellectual property) to Ireland.
(Adapted from https://www.worldfinance.com/wealth-management/top-5-tax-scandals)
Segundo o texto, a principal finalidade do Double Irish era
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Gab. C
The Double Irish arrangement was a base erosion and profit shifting (BEPS) corporate tax avoidance tool used mainly by United States multinationals since the late 1980s to avoid corporate taxation on non-US profits. (3º parágrafo)
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