LLM in International Commercial Law

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Comparative Analysis Between Ireland and the US: Corporation Tax and The Digitalisation of the Economy
(Griffith College, 2022) Borges Cho, Yeda
This dissertation demonstrated a comparative analysis between the corporation tax from Ireland and the United States. The comparison has as a background the digitalisation of the economy indicating a need for changes in the international corporation taxation of multinational groups that no longer need a physical presence to have customers and generate income. This study focused on corporation tax, the BEPS project, the two-pillar solution from OECD/G20, and the global minimum corporation tax rate. The author discussed the view of the OECD concerning tax havens and explained the tax inversion tax planning scheme of American companies in Ireland. This dissertation also indicates how the Double Irish tax avoidance schemes with a Dutch Sandwich and Green Jersey work. The conclusion drawn was that Ireland is not a tax haven, has a better corporation tax system than the United States, and that both countries should embrace de Pillar 1 and 2 solutions proposed by the OECD to tackle the challenges of the digitalisation of the economy.