Super enterprise well versed in tax avoidance techniques: Google Apple Microsoft column

Have to admit, some Super enterprises not only to the development of products, innovative business models skilled avoidance genius.
　　The Paris-based OECD (OECD), in recent years has been studying the way multinational companies through the adjustment of the tax structure as well as to low-tax countries to open branches and legitimate tax avoidance. OECD inventory accounting measures taken by the company in order to avoid tax. From Apple and Google, super company called avoidance genius.
　　The Google using Bermuda achieve avoidance
　　Google is headquartered in Mountain View, California is absolutely avoidance on behalf of the enterprise, only 21% of the nominal tax rate in California is 41%, but Google Inc. in the United States actually paid the tax rate. Google's revenue of $ 12.3 billion, according to the company's 2011 annual report, pay taxes of less than $ 2.6 billion. This is not illegal, the Google operating income in the United States tax law, the lower the tax burden of the company's overall overseas income is mainly due to part to pay taxes at a lower rate - even lower tax rate, tax requirements of the country established overseas branches, the transfer of huge revenue in overseas markets, and to achieve the goal of reducing the overall tax rate.
　　Ireland's tax system is the localization of management, only on their own income and income tax. Irish tax law and allow the ownership and control of an Irish company management is not in the case of their own, can not in Ireland. Ireland and the Netherlands provide that transactions between EU member states, exempt from income tax.
　　This is Google's tax avoidance process: all revenues in Europe are classified to the headquarters of Google in Dublin Ireland. The Google Ireland revenues of 10.1 billion euros in 2010, but statements from the financial point of view, Google's revenue almost because the cost of advertising expenditure and manpower of 2000 employees exhausted. The largest amount of spending 7.2 billion euros, and the license fee paid by Google Ireland, Google Netherlands. According to this model, most of the revenue is stripped from Dublin. Google Ireland need only operating income of 16.8 million euros to pay corporate income tax and employee payroll taxes.
　　Holdings Limited in Amsterdam, the Netherlands, Google, Google Ireland to pay the license fee. However, Google Netherlands is barely a shell company employees only required to pay corporate income tax of 2.7 million euros, Google collected approximately 99.8% of the profits to the Bermuda region (an independent island nation in the western North Atlantic), There is no corporate income tax. As the subsidiary in Bermuda is vested in the actual management of the Irish company management. These revenues and income primarily maneuvers back and forth between the two Irish subsidiary of a Dutch subsidiary, like two pieces of bread sandwiched a cheese sandwich, such a transfer of profits approach known as the "Double Irish" and "Dutch sandwiches. "
　　Such tax avoidance operation is very complicated, but really profitable. This will allow Google to the company's revenue (mainly from advertising) out of Europe, thus making this part of the income almost no tax. This part of the inflow of tax havens in revenue to the U.S. Treasury can not encroach. U.S. regulators only later assigned back to the parent company's income tax. Google has accumulated $ 24.8 billion in tax oasis "Bermuda. According to the information of the six countries in Europe, through the transfer of profits, Google's overseas tax rate dropped to 2.4% is U.S. tech the lowest corporate tax rates in the company.
　　Apple and abroad with "tax sandwiches"
　　Also eat the "tax sandwiches" Apple.
　　Apple reported submitted on October 31 this year, in the fiscal year ended September 29, 2012, the foreign profits of $ 36.8 billion, a year-on-year growth of 53%, paid income tax of $ 713 million, the most recent fiscal year foreign income only turned over to a 1.9% income tax. Fiscal year 2011, the Apple American foreign profits of $ 24 billion, to be turned over to a 2.5% income tax. By contrast, the U.S. corporate income tax is usually 35%.
　　With other large companies, Apple has the cash to stay abroad to avoid repatriation to pay high income tax. Apple before the report submitted to the Securities and Exchange Commission, the company has accumulated $ 121.3 billion in cash and cash equivalents, $ 82.6 billion in overseas accounts.
　　Apple may be in the sales of products of the country to pay a part of the income tax, but it is the use of various accounting methods to minimize the extent of the transfer of profits to low-tax countries. Like Google, the use of the so-called "Double Irish" and "Dutch Sandwich" accounting means profits through Ireland and the Netherlands branch into the Caribbean.
　　Under Irish tax laws, even if it is a company registered in Ireland as long as its parent company, headquartered in a foreign country, was identified as a foreign company. Apple first established in Ireland the Apple international sales company, is responsible for receiving all sales revenue in addition to outside the United States, enjoy Irish income tax of 12.5%. Then Apple set up Apple's international operating companies in Ireland, the headquarters of the company set up in the famous tax havens - British Virgin Islands, there is almost no need to pay income tax.
　　Subsequently, Apple set up Apple's European operating companies in the Netherlands. Ireland and the Netherlands are the provisions transactions between EU member states, are exempt from income tax. Apple only need to pay the entire income transfer process, low transaction tax in the Netherlands and part of the Irish low-income tax.
　　In the United States, Apple also have a way to tax avoidance, we all know Apple's Cupertino headquarters in California, the region's corporate income tax rate is 8.84%, and Nevada, zero. Apple in Reno, Nevada, set up a hedge fund called Braeburn Capital, the company is mainly responsible for receiving and put Apple profits through a tiny office and only a handful of employees dodge tens of millions of California and 20 other states or even hundreds of millions of dollars of tax revenue.
　　If you do not use those tax shelters, Apple last year in the United States may have to pay $ 2.4 billion in federal taxes, according to former U.S. Treasury economist Martin Sullivan's latest research found that. Apple's profit last year was $ 34.2 billion, a total of $ 3.3 billion around the world to pay cash taxes, a tax rate of 9.8%.
　　The Microsoft U.S. territory owned by the IRS tube
　　Similar to Apple, Microsoft, in order to escape the high tax rates of the United States, has set up overseas regional operations center in Ireland, Puerto Rico, Singapore and other countries and regions to the production and distribution of the company's products and services, the tax rate is much lower than the U.S. headquarters. Which Singapore tax rate of 0-17%; Ireland is 12.5%; Puerto Rico, although U.S. possessions, but in the eyes of the IRS, it is an overseas country, Puerto Rico provides substantial tax breaks for multinational companies such as Microsoft.
　　Microsoft in Dublin, Ireland to feature the Round IslandOne and Flat Island two unlimited liability company ", the data from the Chinese MOFCOM in Ireland, Microsoft Ireland in Dublin, up to 9.5 billion euros in sales in 2006, accounting for about 30% of Microsoft's global sales. Microsoft only a few million population in this small country in Europe, if not through a variety of transactions to avoid tax is not possible to achieve such high sales.
　　2011 data show that, in order to avoid the high rate of the United States, Microsoft will be more than 51 billion U.S. dollars to stay overseas, which is mainly in Ireland.
　　A permanent commission of inquiry in the United States Senate, from 2009 to 2011, Microsoft's corporate headquarters in the United States, nearly half of retail sales revenue go to Puerto Rico, involving an amount of $ 21 billion, eliminating the need for a tax of $ 4.5 billion.
　　In addition, these big companies avoidance skills, the license fee is not only a tax avoidance "props" trademark and patent fees is easy money moved into freeing up the grounds. There are a lot of ways to make money is to draw a lot of capital to subsidiaries in tax havens, this part of the money can go to the international financial market investment is almost tax-free.