The link under your quoted line in the TFA seems to be talking about Apple (and others) preparing for the end of the Double Irish by finding other tax havens.

"Elite tax advisers help Apple Inc. and other corporate giants skirt impacts of crackdown on 'Double Irish' maneuvers."

So, I don't see what's invalid about the TFA's point, which is about tax avoidance in general

As someone close to pharmaceutical manufacturing, the reason why the manufacturing is done in Ireland is for tax benefits for sales in Europe.

So why not have a US factory for US sales? Because it's much more expensive and complex to have two separate factories making the same drug. It's far easier to just scale the Irish factory to serve all global sales.

Even the same companies with Irish factories have US factories as well. It's not like any tax benefit moved that out of the US as well.

Switzerland is a whole different matter, but such carelessness doesn't improve trust

EDIT: Sigh, yeah looks like the famous Double Irish loophole closed in 2020, but there's another scheme that's come up since 2021: https://en.wikipedia.org/wiki/Double_Irish_arrangement

E.g. suppose you are a shareholder and receive a dividend of $1000 from some australian public company. If the australian company is large it will be subject to a 30% corporate tax rate. If the company paid company tax on earnings before issuing the dividend, then that dividend comes with a $(1000 / 0.7) * 0.3 = $428.57 tax credit which the shareholder can use to reduce their income tax bill.

That said, in terms of the global landscape of low tax jurisdictions, Australia's corporate tax rate of 30% and highest marginal individual income tax rate of 47% make things less attractive.

This is farcical. The universal response to higher taxes is to create less revenue? Exactly how does this benefit the CEOs salary? Or improve outcomes for shareholders?

> who will pay out profits as salary to themselves rather than reinvesting the money in the company so as to avoid paying taxes on profits twice

The IRS keeps an eye on this. The business owner does not have unlimited runway and the salary selected must be reasonable. It's also not the only tax vehicle available to the owner to reduce or eliminate the "double taxation" that can occur on profit distributions. There's like half a dozen ways to solve this problem from an ownership perspective.

It should also be noted that the personal income tax rate and the capital gains tax rate are likely to offer very different outcomes for the owner. It's hardly as cut and dry as you project.

> A better solution is to slash corporate taxes and raise income taxes on high earners.

So the corporations engage in practices like buybacks and overfund the business and workers wages end up artificially depressed?

A better solution is to examine the problem and respond with appropriately designed policies that are outcome oriented. These "quick fix" and "slash and burn" policies are _precisely_ how we ended up here. Swinging the pendulum all the way to the other extreme creates the same amount of misery just in a different direction.

Your parents medication cost more than a car payment because there's no motivation in the US system to reduce prices for most drugs. Quite the opposite for insurers who provide ACA--they're actually incentivized to increase the cost of care so that the 20% they are allowed to spend on marketing, executive compensation, etc can grow as well.

For this reason a lot of tech companies have subsidiaries in the Nerherlands. Uber is the first example that comes to mind. All card charges when you take an Uber in Europe are to Uber N.V - which is a Dutch Entity.

The Netherland has a decades old strategy of being "business friendly" - if you're a huge corporate.

This culminates in two things. One, The Netherlands has the most tax treaties of any country. This creates many loopholes.

Two, The Netherlands Tax Authority will happily help you take advantage of those. You just have to call them up and say "I plan to sell and lease back some IP through Swasiland, is that OK?" and they will tell you up front whether the loophole you found is OK to use - it's called a "ruling" and it's binding to them. This takes away any concern your tax lawyers might have about being thrown in jail for being too creative.

The basic idea is that The Netherlands would rather help a big corporate avoid paying 10% tax in another country, if it means they pay 1% in The Netherlands. Or even 0% corporate taxes and only some payroll tax for the people working at the Dutch office (job creation for tax lawyers who, as established earlier, lead a stress-free life).

A while back, some executives from the Shell oil company appeared on Dutch television proudly saying "of course we don't pay taxes! Why else would our HQ be here?". This was a bit too rich even for the Dutch viewers, and Shell ended up moving to the UK, presumably after some of their tax rulings got a second look due to political pressure. Unilever similarly left to the UK (who were also giving out tax deals like candy after Brexit ruined their economy).

Note that the author is conflating The Netherlands being a tax haven (which it is) with the location pharmaceuticals are produced.

To take advantage of Dutch tax avoidance strategies, most companies focus on intellectual property; this is why your IKEA pitches has "copyright InterIKEA systems B.V." printed on it. Made in some low wage country, but the license fees for its design are paid to a Dutch for-profit company owned by a non-profit(?) foundation.

In other words, it's easier to produce pharmaceuticals in, say, the Phillipines, and then do some shady (well, pre-approved) accounting to make taxable income disappear into thin air. There's also going to be some importing and re-exporting going on (guess which EU country is home to its biggest port, despite being a tiny country).

Nevertheless, pharma production - or rather "life sciences" - in The Netherlands is one of the governments 9 focus industries. This policy is focused mostly on high-value add activities like R&D rather than production. This will also skew the numbers.

It seems that China is currently a "sink" in the global flow of money, which will obviously change the landscape in the long run. How? Hard to tell, probably not in such a bad as many people fear. I think it will eventually drive up prices of Chinese export goods, which will force importers to look for alternatives, which is likely better in many regards than having one country manufacturing everything for everyone in the world. But don't trust me, I'm just a random poster on the internet.

Well, hope i can educate you with some marx here ;)

https://en.m.wikipedia.org/wiki/Unequal_exchange

Marx theory of equivalence of exchange is the foundation with which he defines exploitation. With a universal comparison unit (value of labor), you can define unbalanced trades.

Dont ask me though, how a balanced trade would look like. Maybe we can only approximate it via outcome.

I do, however, this could be a good idea. But I think the true issue is that we need a globally unified tax framework (and serious retaliation if a nation decides not to adopt it).