Chapter 546： Burger with 3 Meiji

In order to avoid "double taxation" in the United States, Dunn is determined to set up a new global overseas headquarters, so that the company's overseas income can only pay 20%-35% of overseas income tax instead of 20% of US income tax.

This task, Dunn handed over to Chief Financial Officer Brandi Norris.

Brandi Norris went to Europe for a long time, and finally came up with a detailed and shocking investigation report two months later!

"What did you say? Overseas income tax can also be exempted?" Tang En widened his eyes.

Brandy Norris smiled and said: "It is impossible to exempt all, but it can be greatly reduced. If it is done properly, it will only need to pay 2.4% income tax."

Dunn was even more shocked, "2.4%? How is that possible?"

Brandi Norris said: "There are tax havens, you can register different offshore companies as subsidiaries, and then use these different subsidiaries to reverse accounts, transfer income to low-tax tax havens, and spend Move to high-tax countries and regions. Put bluntly, price shifting.”

"Price transfer?"

"Price transfer means that in order to reduce taxes, multinational companies use the tax systems of different jurisdictions to transfer resources in different jurisdictions through pricing between different departments within the company, such as parent company and subsidiary or overseas two subsidiaries. transfer between subsidiaries.”

Dunn took a deep look at Brandi, "Is this reliable? It won't be illegal, right? The EU has been eyeing American companies all the time."

Brandi Norris smiled slightly, "It doesn't matter, this is the common way of taxation of multinational companies. And we have a big advantage, our product is intellectual property. Intellectual property is difficult to price, and there is no unified tax formula for each country. This can be applied, which allows us to use the tax differences between different countries to achieve the purpose of saving taxes.”

Tang En was a little confused. This kind of financial problem is the most complicated. He waved his hand, "Tell me, what should I do?"

Brandy Norris said: "First, establish a new Universal Holding Company in Ireland as the overseas headquarters of the new Universal Group. Since the 1960s, Ireland has pursued the use of low tax rates to attract multinational companies, allowing the use of Ireland to transfer income , pay very little tax.”

“Multinational companies accumulate profits in Ireland and then easily remit the profits to Bermuda. Once the non-US profits of multinational companies enter Bermuda, it is difficult for US regulators to track. Under Irish law, subsidiaries established there do not need to report Financial information including any income statement or balance sheet."

“Then, a new Universal subsidiary was established in Germany, mainly responsible for business processing, through which the intellectual property royalties were paid, and the expenditures reduced the tax payable in Ireland, while the Irish-headquartered company collected licensing fees in the tax haven Bermuda to avoid Ireland tax, I call it a 'double burger' structure."

"Through this 'Irish-German double burger' structure, the overseas income tax can be reduced to 12.5%. This is not enough. Since the Irish tax law exempts withholding tax only for EU member companies, the new Universal is not part of the EU. In order to avoid Irish withholding tax, the payments from the German subsidiary do not go directly to Bermuda, but instead go through a shell company with no employees in the Netherlands.”

“The Netherlands has a relaxed tax policy, and the Dutch shell company will transfer about 99.8% of its royalties to Bermuda. Through the Irish headquarters that holds the intellectual property, the German subsidiary responsible for business processing, and the shell Dutch subsidiary, you can Easy tax avoidance. I call it a 'Dutch sandwich' structure."

Dunn looked at Brandi Norris talking, and felt his confidence. He was also dizzy for a while. He only knows that the head office in Ireland is responsible for the sale of intellectual property rights, the subsidiary in Germany is responsible for specific business processing, the subsidiary in the Netherlands is Airbus, and the subsidiary in Bermuda is completely stranded, evading the supervision of the US Department of Justice .

Tang En coughed lightly, "Long story short, how much tax can we avoid?"

Brandy Norris said: "Through this operation, 88% of the operating profits of German companies can be transferred to tax havens, and only the remaining 12% of profits can be paid for income tax. On average... Our overseas Income, only need to pay 2.4% income tax. Based on the revenue of New Universal Group this year, if we use this structure, this year ... at least 1.5 billion US dollars in tax expenses can be saved!"

"$1.5 billion!"

Dunn took a deep breath and said, "Okay! Brandi, tell Barry about this matter, that's all, start the 'burger' and 'sandwich' plan immediately. Next year, the reorganization of the New Universal Group will also be It’s over, our overseas income must have reasonable tax avoidance methods!”

"no problem!"

"Well, by the way, do you know about the usa TV network?"

Brandy Norris is not only the head of overseas headquarters planning, but also the chief financial officer of the New Universal Group. Barry Diller must communicate with him if he wants to sell the usa TV network.

"It's hard!" Brandi Norris was cautious. "The usa TV network has changed hands twice within a year, which has caused instability, and it is difficult for a company to take over. Especially now that Viacom is targeted So strong, the prospects of the usa TV network are not optimistic. The top priority is not to rush to sell the usa TV network, but to find a way to make the usa TV network survive under the suppression of Viacom. "

"well said!"

Dunn sighed in admiration.

In this matter, Dunn and Barry Diller had some differences. The latter believes that it should be shot immediately, even if the price is lower, but also to get rid of the burden of the usa TV network, and put more energy into potential businesses.

Barry Diller and Jack Welch have been working together for many years, and are deeply influenced by his principle of "one of the best", that is, if this business has no chance of becoming the first or second in the industry, it must be abandoned immediately. Do not hesitate!

But Dunn doesn't want to make a loss-making business.

usa TV network, it's not that it can't be sold, but it can't be sold at a low price; it's not that it can't be saved, it's just a little troublesome.

He had foresight.

After these few years have passed, and Viacom has been destroyed, the spring of the usa TV network will come.

At that time, whether the usa TV network is sold or reorganized can be left to its own discretion.

...

Just like the general opinion in the industry.

usa television network, under the target of mtv television network, there is no possibility of any resistance. In just one week, usa television network has lost more than 300,000 household users.

Barry Diller was a little impatient, "Dawn, I think I can accept Comcast's $3.2 billion offer to sell the usa TV network!"

Dunn laughed angrily, "$3.2 billion? Barry, don't you think this is an insulting offer? Comcast is singing a double reed with Viacom!"

Last year, Vivendi acquired the usa TV network for $10.3 billion. This year, the usa TV network sold it to Dunn for another $4.5 billion.

In this transaction, Vivendi made the whole world laugh.

Just two months later, Dunn will sell the usa TV network for $3.2 billion?

Isn't New Universal equal to Vivendi? Become a laughing stock?

Barry Diller frowned, "Dawn, we are businessmen, we can't be emotional, the usa TV network is in a great crisis now!"

Dunn disapproved and sneered: "Comcast wants to take advantage of the fisherman, it's just a dream! Even if the usa TV network rots in my hands, I can't sell it to Comcast at a low price! Unless they can offer 50 One hundred million U.S. dollars!"

Barry Diller's face was a little ugly.

$5 billion?

Simply fantastic.

The whole of the United States knows that the usa TV network has become a thorn in Redstone's eyes. At this time, Comcast is willing to buy it, it is already very good.

It's simply impossible to spend more than $3 billion on a risky cable network with another company.

"Barry, Jeff Zucker jumped over to take over the TV and media department because I gave him a promise. I promised him that the new Universal Group would focus on developing the TV and media department in the next few years. I can't break my promise, right? He just joined , I sold the usa TV network, I can't explain to him Dunn said earnestly.

Barry Diller said indifferently: "He is a businessman with qualified business thinking, and he can understand the decision-making of the group."

Tang En shook his head and said: "Maybe he has enough professionalism, but I can't keep my word. Besides, usa TV network... It's not really hopeless. As long as it is handled properly, it can be a bright spot!"

"Oh?"

Barry Diller's eyes lit up.

Because of his complicated relationship with Michael Eisner, Dunn is currently in charge of the cooperation between New Universal and Disney.

But he also knew some secret operations of Dunn in private.

"You mean 'American Idol'?"

"Hmph, Redstone wants to play, so I'll play with him! In any case, the second season of "American Idol" can no longer be run by cbs!"

Barry Diller squinted, "Viacom's stock price this year is very stagnant, on the one hand because the competition with Disney has intensified, on the other hand, the contradiction between Redstone and Mayer Kamathin has made investors Concerned. If we announce at this time that American Idol is no longer working with cbs on season two..."

Dunn waved his hand, "Don't worry! I've already made an appointment with Michael Eisner. I'll talk to him first! "American Idol" is a heavy weapon, and I can't give it to Disney for nothing."

"You mean... usa TV network?"

"That's right!"

The usa television network targeted by the mtv television network has severely squeezed the living space. If you want to survive in this situation, looking at the cable networks in the United States, it is estimated that only CNN and espn can solve it.

Dunn has a general relationship with Time Warner, but his relationship with Disney is complicated.

usable!

7

(Sanqi Chinese)