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XPC IRELAND

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by

Aleksandra Susek

on 26 May 2017

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Transcript of XPC IRELAND

XPC IRELAND
XPC USA
XPC DEVELOPMENT (USA)
XPC UK
OFFICE
XPC MEXICO
XPC CHINA
XPC MALAYSIA
XPC INDONESIA
XPC TAIWAN
XPC BERMUDA
SELLING IP
DIVIDEND £20 M
RAW
MATERIALS
DATA
RAW
MATERIALS
UK WAREHOUSE
IRELAND WAREHOUSE
WORLDWIDE
SALES COMPANIES
Shift in all the expenses to high tax territory
Profit taxed at lower rate in low tax territory
Protection from extra tax liability
IP RIGHTS
ROYALTIES
Tax exempt income accrued from royalties
ROYALTIES
Expenses treated as tax deductibles
MANUFACTURING SUBSIDIARIES
Share of IP use profits between USA, Bermuda and Manufacturing subsidiaries
Limited interest paid and restricted profit shifting
XPC GROUP
IP interest payments reduce profit liable to tax
Mandated transparent tax planning and practices
Country-by-country reporting
Interests and royalties drain profits from all Group entities
Associated profits taxed at 30%
Tax implication on profits due to PE status

Tax implication on profits
due to PE status
RECOMMENDATIONS

XPC Bermuda - transfer IP ownership to XPC Ireland (enhancement, maintenance protection )

XPC Bermuda to be closed


XPC Ireland - sell the raw materials and buy the finished goods


PAYMENT FOR A DATA

SUPPLY OF MOBILE PHONES AND TABLETS
FINISHED PRODUCTS

XPC UK - change from branch to subsidiary


XPC Development - to be made
a branch of XPC USA

XPC Group - convert sales companies
into independent agents




COST CONTRIBUTION £ 75k
Full transcript