Re: Double Irish With A Dutch Sandwich - it's dead(ish) Jim
Nope, the Irish government closed their part of the loophole in 2015 and pre-existing structures can only run until 2020.
Sure the particular instance of that strategy has issues, but don't for one second assume that any more tax will be payable. My business unit are already migrating whats left of our version of this to something else. Rather obviously, I can't tell you specifically what. I can tell you that nobody is expecting to leave Ireland as a result of the changes, and that Ireland isn't expecting to garner any extrat tax revenue from the change - its only being implemented to appease the EU.
Holland is still the best place for royalties (U2 still have their hedgefund there I believe), and Delaware is still Delaware. For as long as a company is taxed on profits, moving them via trade, loans, or IP will always ensure most of the profit ends up where its taxed less.
The Irish jig is missing several steps to be a properly aggressive strategy anyway - its just the one the papers know about. A proper strategy leaves you a tax loss in the expensive jurisdictions (double dipping the money-go-round enables simultaneous loss claims, its just harder than it used to be) as well as profit in a tax free location. Tax losses are more valuable in some respects than taxable profit, because you can offset it for 100% of the gain when you decide you need to make profit somewhere, or package it up and flog the vehicle to someone who needs to declare an onshore profit.