Netflix Accused Of Funnelling $430M Of International Profits Into Tax Havens

It’s really not that simple. What you just described can’t happen. A US parent company can’t license IP from a foreign subsidiary without tripping subpart F rules.

I also think people don’t appreciate that the countries of the world are starting to crack down on tax avoidance abuse. Ireland has done away with a lot of their structures that facilitated tax avoidance due to state aid rulings from the EC. The EU is cracking down on tax havens via ATAD I and II. The UK is cracking down on IP licensing structures with ORIP. And the OECD is moving forward with Pillars 1 and 2 (though it looks like the US will veto Pillar 1 since its “unfairly” targeting US-based businesses and dismisses the arm’s length standard).

The solutions are slow and imperfect, but international tax is a lot more complicated than most people appreciate and countries are making strides in the right direction.

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