While undergoing my undergraduate degree in law, I had already decided to pursue my thesis on Tax Avoidance since it is a legal way albeit immoral one to curtail the amount of tax an institution has to pay. And it was during that time, big multinational corporates were being busted for avoiding tax by using a novel scheme, "The Double Irish and Dutch Sandwich". A funny name, though it spells out clearly how the scheme works. One just has to route one's money through two irish companies and a dutch one. My thesis mainly explored how Apple Inc. was avoiding tax.
Companies using this scheme enable the transfer of a large amount of their profits to offshore tax havens by using wholly owned subsidiaries located in Ireland and the Netherlands. This paper also analyzes the United States General Anti-Avoidance Rule to see whether it can effectively detect and counteract this scheme. This analysis is furthermore enhanced by applying the Mauritian General Anti-Avoidance Rule through Section 90 of the Income Tax Act to the said scheme. The paper then concludes that it is possible to counteract the scheme using the Mauritian law but under specific circumstances. It is then revealed that there is a fundamental flaw in the current tax systems, which is the inability to regulate the intangible nature of resources, and technology based transactions.
If my brief summary above captivated you enough, check out my thesis below.