A corporate haven, corporate tax haven, or multinational tax haven, is a jurisdiction that multinational corporations find attractive for establishing subsidiaries or incorporation of regional or main company headquarters, mostly due to favourable tax regimes, and/or favourable secrecy laws, and/or favourable regulatory regimes.
BHP, formerly known as BHP Billiton, is the trading entity of BHP Group Limited and BHP Group plc, an Anglo-Australian multinational mining, metals and petroleum dual-listed public company headquartered in Melbourne, Victoria, Australia.
The International Financial Services Centre began in 1987 as a special economic zone on a derelict 11 hectare site near the centre of Dublin, with EU approval to apply a 10% corporate tax rate for designated financial services activities on the site. Before the expiry of this EU approval in 2005, the Irish Government legislated in 1998/99 to effectively "turn the entire country into an IFSC" by reducing the overall Irish corporate tax rate from 32% to 12.5%. The legal requirement for a specific IFSC geographic area was thus removed, and the term International Financial Services ("IFS") sector is now sometimes used.
Ireland's Corporate Tax System is a central component of Ireland's economy. In 2016–17, foreign firms paid 80% of Irish corporate tax, employed 25% of the Irish labour force, and created 57% of Irish OECD non-farm value-add. U.S.–controlled firms represent almost all foreign firms in Ireland and in 2017 were 25 of the top 50 Irish firms, and 70% of the revenue of the top 50 Irish firms. By 2018, Ireland had received the most U.S. § Corporate tax inversions in history, and Apple was over one–fifth of Irish GDP. Academics rank Ireland as the largest tax haven; larger than the Caribbean tax haven system.
Jacques A. Nasser is a Lebanese Australian American business executive and philanthropist. Known for a management career at Ford Motor Company spanning several decades and continents, from 1999 to 2001 he served as Ford's CEO and president. He subsequently was a partner at One Equity Partners (JPMorgan) and on the board of British Sky Broadcasting. He was Chairman of the Australian mining company BHP Billiton from 2010 to September 2017. On 5 December 2012, Smart Company named Nasser No. 6 on a list of the "most powerful people in Australian boardrooms." He currently serves on the boards of 21st Century Fox and Koç Holding. A member of both the National Order of the Cedar in Lebanon and the Order of Australia, Nasser was also awarded the Ellis Island Medal of Honor, which pays homage to contributions made to America by immigrants. Nasser funds several scholarship programs that assist individual students.
Cerrejón is a large open-pit coal mine in Colombia. It is located in the southeast of the department of La Guajira, close to the border with Venezuela. The coal mine is situated in the northeastern part of the Cesar-Ranchería Basin, the basin of the Ranchería River, between the Sierra Nevada de Santa Marta in the west and the Serranía del Perijá to the southeast. At Cerrejón, low-ash, low-sulphur bituminous coal from the Cerrejón Formation is excavated. The mine is one of the largest of its type, the largest in Latin America and the tenth biggest in the world. Cerrejón extends over 690 square kilometres (270 sq mi). It is divided into three sections, North Zone, Central Zone and South Zone. Total proven reserves are estimated at 503 megatonnes. In 2016, the mine produced 32,683,315 tonnes.
Paladin Energy Ltd is a Western Australian based uranium production company.
Charles Waterhouse "Chip" Goodyear IV is the former CEO of BHP Billiton and a member of the Goodyear family that had extensive business interests in lumber and railways as well as significant philanthropic endeavors.
A tax haven is generally defined as a country or place with very low "effective" rates of taxation for foreigners. In some traditional definitions, a tax haven also offers financial secrecy. However, while countries with high levels of secrecy but also high rates of taxation, can feature in some tax haven lists, they are not universally considered as tax havens. In contrast, countries with lower levels of secrecy but also low "effective" rates of taxation, appear in most § Tax haven lists. The consensus around effective tax rates has led academics to note that the term "tax haven" and "offshore financial centre" are almost synonymous.
The Minerals Resource Rent Tax (MRRT) was a tax on profits generated from the mining of non-renewable resources in Australia. It was a replacement for the proposed Resource Super Profit Tax (RSPT).
The Double Irish is a base erosion and profit shifting ("BEPS") corporate tax tool, used mostly by U.S. multinationals since the late 1980s, to avoid corporate taxation on most non–U.S. profits. It is the largest tax avoidance tool in history and by 2010, was shielding US$100 billion annually in U.S. multinational foreign profits from taxation, and was the main tool by which U.S. multinationals built up untaxed offshore reserves of US$1 trillion from 2004 to 2018. Traditionally, it was also used with the Dutch Sandwich BEPS tool, however, changes to Irish tax law in 2010 dispensed with this requirement for most users.
Some of the more notable coal companies in Australia are the following:
Transfer mispricing, also known as transfer pricing manipulation or fraudulent transfer pricing, refers to trade between related parties at prices meant to manipulate markets or to deceive tax authorities. The legality of the process varies between tax jurisdictions; most regard it as a type of fraud or tax evasion.
Base erosion and profit shifting (BEPS) refers to corporate tax planning strategies used by multinationals to "shift" profits from higher–tax jurisdictions to lower–tax jurisdictions, thus "eroding" the "tax–base" of the higher–tax jurisdictions. The Organisation for Economic Co-operation and Development (OECD) define BEPS strategies as also: "exploiting gaps and mismatches in tax rules"; however, academics proved corporate tax havens, who are the largest global BEPS hubs, use OECD–whitelisted tax structures and OECD–compliant BEPS tools. Corporate tax havens offer BEPS tools to "shift" profits to the haven, and additional BEPS tools to avoid paying taxes within the haven. BEPS tools are mostly associated with U.S. technology and life science multinationals. Tax academics showed use of the BEPS tools by U.S. multinationals, via tax havens, maximised long–term U.S. exchequer receipts and shareholder return, at the expense of others.
The Tax Attractiveness Index (T.A.X.) indicates the attractiveness of a country’s tax environment and the possibilities of tax planning for companies. The T.A.X. is constructed for 100 countries worldwide starting from 2005 on. The index covers 20 equally weighted components of real-world tax systems which are relevant for corporate location decisions. The index ranges between zero and one. The more the index values approaches one, the more attractive is the tax environment of a certain country from a corporate perspective. The 100 countries include 41 European countries, 19 American countries, 6 Caribbean countries, 18 countries that are located in Africa & Middle East, and 16 countries that fall into the Asia-Pacific region.
On 29 August 2016, after a two-year EU investigation, Margrethe Vestager of the European Commission announced: "Ireland granted illegal tax benefits to Apple". The Commission ordered Apple to pay €13 billion, plus interest, in unpaid Irish taxes from 2004–14 to the Irish State. It was the largest corporate tax fine in history. On the 7 September 2016, the Irish State secured a majority in Dail Eireann to reject payment of the back-taxes, which including penalties, could reach €20 billion, or 10% of 2014 Irish GDP. In November 2016, the Irish State formally appealed the ruling, claiming there was no departure from Irish taxation law, and that the Commission's action was "an intrusion into Irish sovereignty", as national tax policy is excluded from EU treaties. In November 2016, Apple CEO Tim Cook, announced Apple would appeal, and in September 2018, Apple lodged €13 billion to an escrow account, pending appeal.
Ireland is labelled a tax haven or corporate tax haven, which it rejects. Ireland's base erosion and profit shifting ("BEPS") tools give foreign corporates § Effective tax rates of 0% to 3% on global profits re-routed to Ireland via Ireland's tax treaty network. Ireland's aggregate § Effective tax rates for corporates is circa 2–4%. Ireland's BEPS tools are the world's largest BEPS flows, exceed the entire Caribbean system, and artificially inflate the US–EU trade deficit. Ireland's QIAIF & L–QIAIF regimes, and Section 110 SPVs, enable foreign investors to avoid Irish taxes on Irish assets, and can be combined with Irish BEPS tools to create confidential routes out of the Irish corporate tax system. As these structures are OECD–whitelisted, Ireland uses data protection, data privacy laws, and opt-outs from filing of public accounts, to obscure their effects. There is evidence Ireland acts as a § Captured state fostering tax avoidance strategies.
