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Re:Google used ‘double-Irish’ to shift $75.4B in profits out... by vmception on Saturday April 17, 2021 @09:31PM (#26849014)
I agree because of the huge gulf of experiences different people have with tax authorities.

From what I can tell, most people have an adversarial relationship with tax authorities, and therefore assume any more beneficial advantage is a "loophole" like something that would even surprise the tax authorities, when a reality is that many people and organizations have a collaborative relationship with tax authorities.

Transfer pricing requires pre-emptive approval from the tax authorities involved. You are basically telling them how you won't pay taxes and they sign off on it, specifically the nature of the transaction and coming to an agreement on how it complies. Greater disdain from the general population can come from understanding how expensive that can be to collaborate with the tax authority, but I don't think that changes anything. It doesn't give a better argument with any nuance.

My tax opinion isn't based on a country passively deserving anything from the mere existence of a transaction, tax authorities aren't operating that way either and neither are the legislatures. My understanding of the tax topics seems to be more compatible and effective than what I hear from most people, just like the lawyers and CFOs of these fortune 500 companies.

Re:Google used ‘double-Irish’ to shift $75.4B in profits out... by MrPowers on Saturday April 17, 2021 @09:35PM (#26849028)
Definitely don't agree with "Transfer pricing requires pre-emptive approval from the tax authorities involved". Maybe you're thinking about an Advanced Pricing Agreement. Transfer pricing is the pricing of goods and services between related parties in different tax jurisdictions (multinationals typically).
Re:Google used ‘double-Irish’ to shift $75.4B in profits out... by vmception on Saturday April 17, 2021 @10:05PM (#26849189)
I am thinking about APAs. Wouldn't transfer pricing involve an APA while APAs can also be for other things.