Aligning Commercial And Tax Objectives

08 November 2012

In this interview taken at the marcus evans Tax Officers Summit XIV 2012, John Gulliver, Head of Tax at Mason Hayes & Curran, highlights why Tax Officers should move away from offshore zero tax plans.

Adopting tax strategies that involve Ireland as an onshore European Union Organization for Economic Co-operation and Development compliant location will help Tax Officers plan for international taxation challenges, says John Gulliver, Head of Tax at Irish law firm Mason Hayes & Curran. These strategies should be structured around the true commercial drivers of their organizations, he adds.

For the upcoming marcus evans Tax Officers Summit XIV 2012, in Las Vegas, Nevada, November 8-10, Gulliver, who specializes in international tax planning for multi-nationals involving Ireland, advises Tax Officers to review annually their international structures as a titanic shift in international tax controversy is currently underway.

How can Tax Officers prepare for international tax planning?

Tax Officers should ensure that international tax plans reflect continually the underlying commercial realities of the business.

An Irish onshore tax presence should be part of any Tax Officer's international tax strategy.

What are your expectations for the US federal and state tax systems?

Tax controversy between the US Internal Revenue Service and foreign Revenue Services will increase and without adequate defense measures, will put pressure on multi-nationals after tax consolidated earnings.

What further advice can you give looking forward?

Tax Officers need to prepare for their international tax strategies being challenged. A key defence to such challenges is to ensure that the underlying detailed legals support an onshore low tax operating platform on a similar basis to transactions between unrelated parties. The mere provision of transfer pricing reports divorced from the underlying legal and commercial matrix will not easily withstand challenge.

The tax strategy must follow the commercial strategy, and not the other way around.

For further information, please contact John Gulliver at or +353 1 614 5007.

For more information about this event, please click here.   

The content of this article is provided for information purposes only and does not constitute legal or other advice. Mason Hayes & Curran ( is a leading business law firm with offices in Dublin, London and New York.
© Copyright Marcus Evans Summits 2012.  All rights reserved.

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