A special-purpose entity ( SPE ; or, in Europe and India, special-purpose vehicle / SPV ; or, in some cases in each EU jurisdiction, FVC , financial vehicle corporation ) is a legal entity (usually a limited company of some type or, sometimes, a limited partnership ) created to fulfill narrow, specific or temporary objectives. SPEs are typically used by companies to isolate the firm from financial risk . A formal definition is "The Special Purpose Entity is a fenced organization having limited predefined purposes and a legal personality".
76-657: Indian Railway Stations Development Corporation Limited (IRSDC) was a special purpose vehicle owned by the Rail Land Development Authority (RLDA), Ircon International and RITES . All three companies are owned by the Indian Ministry of Railways . IRSDC was incorporated on 12 April 2012. On 18 October 2021, as part of a measure to rationalise railway bodies, the Railway Board announced that it would shut down IRSDC, and transfer
152-664: A § Top 10 tax havens in all three quantitative lists, Hines 2010, ITEP 2017 and Zucman 2018 (above); all nine such § Top 10 tax havens are listed below. (♣) Appears on the James Hines 2010 list of 52 tax havens; 17 of the 20 locations below, are on the James Hines 2010 list. (Δ) Identified on the largest OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); only four locations below were ever on an OECD list. (↕) Identified on
228-479: A SPV named SITCO. This unique initiative is being spearheaded by Indian Railways Station Development Corporation which has been entrusted to implement the task of Railway Station development/redevelopment projects of the Ministry of Railways. This project once completed, will transform the face of Surat. Request for Qualification cum Request for Proposal (RFQ cum RFP) for appointment of Developer to take up
304-406: A consequence they have few bilateral tax treaties . Modern corporate tax havens have non-zero "headline" rates of taxation and high levels of OECD compliance, and thus have large networks of bilateral tax treaties. However, their base erosion and profit shifting ("BEPS") tools enable corporates to achieve "effective" tax rates closer to zero, not just in the haven but in all countries with which
380-479: A hybrid "territorial" tax system, and proposed EU Digital Services Tax regime, and EU Common Consolidated Corporate Tax Base ). While areas of low taxation are recorded in Ancient Greece, tax academics identify what we know as tax havens as being a modern phenomenon, and note the following phases in their development: There is no established consensus regarding a specific definition for what constitutes
456-486: A list of 52 tax havens , which he had scaled quantitatively by analysing corporate investment flows. Hines' largest havens were dominated by corporate tax havens, who Dharmapala noted in 2014 accounted for the bulk of global tax haven activity from BEPS tools. The Hines 2010 list was the first to estimate the ten largest global tax havens, only two of which, Jersey and the British Virgin Islands, were on
532-534: A loss of tax revenues to countries which are not tax havens. Estimates of the § Financial scale of taxes avoided vary, but the most credible have a range of US$ 100–250 billion per annum. In addition, capital held in tax havens can permanently leave the tax base (base erosion). Estimates of capital held in tax havens also vary: the most credible estimates are between US$ 7–10 trillion (up to 10% of global assets). The harm of traditional and corporate tax havens has been particularly noted in developing nations, where
608-456: A narrow set of goals without putting the entire firm at risk. SPEs are also commonly used in complex financings to separate different layers of equity infusion. Commonly created and registered in tax havens , SPEs allow tax avoidance strategies unavailable in the home district. Round-tripping is one such strategy. In addition, they are commonly used to own a single asset and associated permits and contract rights (such as an apartment building or
684-452: A power plant), to allow for easier transfer of that asset. They are an integral part of public private partnerships common throughout Europe which rely on a project finance type structure. A special-purpose entity may be owned by one or more other entities and certain jurisdictions may require ownership by certain parties in specific percentages. Often it is important that the SPE is not owned by
760-625: A tax haven also offers financial secrecy . However, while countries with high levels of secrecy but also high rates of taxation, most notably the United States and Germany in the Financial Secrecy Index (FSI) rankings, can be featured in some tax haven lists, they are often omitted from lists for political reasons or through lack of subject matter knowledge. In contrast, countries with lower levels of secrecy but also low "effective" rates of taxation, most notably Ireland in
836-544: A tax haven. This is the conclusion from non-governmental organisations , such as the Tax Justice Network in 2018, from the 2008 investigation by the U.S. Government Accountability Office , from the 2015 investigation by the U.S. Congressional Research Service , from the 2017 investigation by the European Parliament, and from leading academic researchers of tax havens. The issue, however,
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#1732791447528912-529: Is focused on quantitative analysis (which can be ranked), and tends to ignore very small tax havens where data is limited as the haven is used for individual tax avoidance rather than corporate tax avoidance. The last credible broad unranked list of global tax havens is the James Hines 2010 list of 52 tax havens. It is shown below but expanded to 55 to include havens identified in the July 2017 Conduit and Sink OFCs study that were not considered havens in 2010, namely
988-422: Is material, as being labelled a "tax haven" has consequences for a country seeking to develop and trade under bilateral tax treaties. When Ireland was "blacklisted" by G20 member Brazil in 2016, bilateral trade declined. One of the first § Important papers on tax havens , was the 1994 Hines–Rice paper by James R. Hines Jr. It is the most cited paper on tax haven research, even in late 2017, and Hines
1064-412: Is no connection with the sponsor. Some of the reasons for creating special-purpose entities are: Like a company, an SPE must have promoter(s) or sponsor(s). Usually, a sponsoring corporation hives off assets or activities from the rest of the company into an SPE. This isolation of assets is important for providing comfort to investors. The assets or activities are distanced from the parent company, hence
1140-405: Is quite common for tanker fleets to have each tanker owned by a separate special-purpose entity to try to avoid group liability in relation to widely drawn anti-pollution laws. Tax haven A tax haven is a term, often used pejoratively, to describe a place with very low tax rates for non-domiciled investors , even if the official rates may be higher. In some older definitions,
1216-437: Is the most cited author on tax haven research. As well as offering insights into tax havens, it took the view that the diversity of countries that become tax havens was so great that detailed definitions were inappropriate. Hines merely noted that tax havens were: "a group of countries with unusually low tax rates". Hines reaffirmed this approach in a 2009 paper with Dhammika Dharmapala . In December 2008, Dharmapala wrote that
1292-537: The Cayman Islands , as Google, Facebook and Apple do not appear on Orbis. Even so, Zucman's 2018 list of top 10 havens also matched 9 of the top 10 havens in Hines' 2010 list, but with Ireland as the largest global haven. These lists (Hines 2010, CORPNET 2017 and Zucman 2018), and others, which followed a purely quantitive approach, showed a firm consensus around the largest corporate tax havens. In October 2009,
1368-515: The Enron scandal of 2001 . They were also used to hide losses and overstate earnings by executives at Towers Financial Corporation , which declared bankruptcy in 1994. Several executives of the company were found guilty of securities fraud, served prison sentences, and paid fines. Evergrande has also been accused of using off book SPE to hide debt. Under US GAAP , a number of accounting standards apply to SPEs, most notably FIN 46R that sets out
1444-402: The Financial Secrecy Index ), but not on corporate tax haven or traditional tax haven lists, are: Neither the U.S. nor Germany have appeared on any tax haven lists by the main academic leaders in tax haven research, namely James R. Hines Jr. , Dhammika Dharmapala , or Gabriel Zucman . There are no known cases of foreign firms executing tax inversions to the U.S. or Germany for tax purposes,
1520-836: The NBER listed the key tax havens as: "Ireland, Luxembourg, Netherlands, Switzerland, Singapore, Bermuda and [the] Caribbean havens". (*) Appears as a top ten tax haven in all three lists; 9 major tax havens meet this criterion, Ireland, Singapore, Switzerland and the Netherlands (the Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the Sink OFCs) . (†) Also appears as one of 5 Conduit OFC (Ireland, Singapore, Switzerland,
1596-754: The OCDE . CRS countries require banks and other entities to identify the residence of account holders, beneficial owners of corporate entities and record yearly account balances and communicate such information to local tax agencies, which will report back to tax agencies where account holders or beneficial owners of corporations reside. CRS intends to end offshore financial secrecy and tax evasion giving tax agencies knowledge to tax offshore income and assets. However very large and complex corporations, like multinationals , can still shift profits to corporate tax havens using intricate schemes. Traditional tax havens, like Jersey , are open about zero rates of taxation – as
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#17327914475281672-403: The Tax Justice Network introduced the Financial Secrecy Index ("FSI") and the term "secrecy jurisdiction", to highlight issues in regard to OECD-compliant countries who have high tax rates and do not appear on academic lists of tax havens, but have transparency issues. The FSI does not assess tax rates or BEPS flows in its calculation; but it is often misinterpreted as a tax haven definition in
1748-605: The § Top 10 tax havens lists, namely: Caribbean tax havens (e.g., Bermuda, the British Virgin Islands, and the Cayman Islands), Channel Islands tax havens (e.g. Jersey) and Asian tax havens (e.g., Singapore and Hong Kong). As discussed in § History , the United Kingdom created its first "non-resident company" in 1929, and led the Eurodollar offshore financial centre market post–World War II. Since
1824-430: The 2015 U.S. Congressional Research Service investigation into tax havens, as being restrictive, and enabling Hines' low-tax havens (i.e. to which the first criterion applies), to avoid the OECD definition by improving OECD cooperation (so the second and third criteria do not apply). Thus, the evidence (limited though it undoubtedly is) does not suggest any impact of the OECD initiative on tax-haven activity. [...] Thus,
1900-708: The European Union's first 2017 list of 17 tax havens; only one location below is on the EU 2017 list. Sovereign states that feature mainly as major corporate tax havens are: Sovereign states or autonomous regions that feature as both major corporate tax havens and major traditional tax havens: Sovereign (including de facto) states that feature mainly as traditional tax havens (but have non-zero tax rates): Sovereign or sub-national states that are very traditional tax havens (i.e. explicit 0% rate of tax) include (fuller list in table opposite): Post–2010 research on tax havens
1976-461: The FSI rankings, appear in most § Tax haven lists . The consensus on effective tax rates has led academics to note that the term "tax haven" and " offshore financial centre " are almost synonymous. In reality, many offshore financial centers do not have harmful tax practices and are at the forefront among financial centers regarding AML practices and international tax reporting. Developments over
2052-844: The Great Indian Peninsular Railways , UOI Vs. UPSEB, 2001 etc.). According to the Original Indian Railways Permanent Way Manual (IRPWM) - "Section 11 of the Indian Railways Act No.24 of 1989 and the Government Buildings Act No. IV of 1899 read in conjunction with Sec.291 of the Cantonments Act No. II of 1924 provide for the right to erect buildings on their own land by Railways without having to obtain sanction of
2128-535: The Indian Railway Station Development Corporation (IRSDC) to convert Chandigarh railway station into world-class facility." "A senior Railway Ministry official said that the ₹8.5-lakh-crore railway infrastructure modernisation plan has been attracting a number of private companies. IRSDC has roped in one of the top global consulting firms to prepare a business plan for station modernisation." "The railways has chalked out
2204-516: The Municipal or Cantonment authorities in whose area the site is situated ." This facility in law available to IRSDC is of great essence, as the lack of it assails the capability of the private developers to secure approvals and execute the redevelopment efforts within strict timelines in order to maintain project IRRs. Nevertheless, in fairness of things, the IRPWM also states that - "In urban areas,
2280-520: The Netherlands, and the United Kingdom), in CORPNET's 2017 research; or (‡) Also appears as a Top 5 Sink OFC (British Virgin Islands, Luxembourg, Hong Kong, Jersey, Bermuda), in CORPNET's 2017 research. (Δ) Identified on the first, and largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017). The strongest consensus amongst academics regarding
2356-667: The OECD initiative cannot be expected to have much impact on corporate uses of tax havens, even if (or when) the initiative is fully implemented In April 2000, the Financial Stability Forum (or FSF) defined the related concept of an offshore financial centre (or OFC), which the IMF adopted in June 2000, producing a list of 46 OFCs . The FSF–IMF definition focused on the BEPS tools havens offer, and on Hines ' observation that
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2432-410: The OECD process had removed much of the need to include "bank secrecy" in any definition of a tax haven and that it was now "first and foremost, low or zero corporate tax rates", and this has become the general "financial dictionary" definition of a tax haven. Hines refined his definition in 2016 to incorporate research on § Incentives for tax havens on governance, which is broadly accepted in
2508-609: The OECD's 2000 list. In July 2017, the University of Amsterdam 's CORPNET group ignored any definition of a tax haven and focused on a purely quantitive approach, analysing 98 million global corporate connections on the Orbis database . CORPNET's lists of top five Conduit OFCs , and top five Sink OFCs , matched 9 of the top 10 havens in Hines' 2010 list, only differing in the United Kingdom, which only transformed their tax code in 2009–12 . CORPNET's Conduit and Sink OFCs study split
2584-511: The OECD's new Global Forum on Transparency and Exchange of Information for Tax Purposes , and therefore would not meet Criteria ii and Criteria iii . As the OECD has never listed any of its 35 members as tax havens, Ireland, Luxembourg, the Netherlands, and Switzerland are sometimes defined as the "OECD tax havens". In 2017, only Trinidad & Tobago met the 1998 OECD definition; that definition thus fell into disrepute. (†) The 4th criterion
2660-580: The Project may be awarded. Brief particulars of the Project are as follows: (INR. bn.) (Cost excluding commercial development) On 22 February 2016, the official Twitter page , LinkedIn page and the Facebook page of IRSDC reported, vide an official press release, that the RFQ applications for Anand Vihar had been received. The response, that included 13 applications as against 3 applications for Habibganj,
2736-465: The United Kingdom) were cited as the world's leading tax havens. The longest list from Non-governmental, Quantitative research on tax havens is the University of Amsterdam CORPNET July 2017 Conduit and Sink OFCs study, at 29 (5 Conduit OFCs and 25 Sink OFCs). The following are the 20 largest (5 Conduit OFCs and 15 Sink OFCs), which reconcile with other main lists as follows: (*) Appears in as
2812-427: The United Kingdom, Taiwan, and Curaçao. The James Hines 2010 list contains 34 of the original 35 OECD tax havens; and compared with the § Top 10 tax havens and § Top 20 tax havens above, show OECD processes focus on the compliance of tiny havens. (†) Identified as one of the 5 Conduits by CORPNET in 2017; the above list has 5 of the 5. (‡) Identified as one of the largest 24 Sinks by CORPNET in 2017;
2888-615: The Urban Development Authority must be consulted and rules framed by them followed. Municipal or Local authorities may, however, be consulted, where appropriate, regarding water connections, sewer lines and sewage disposal and similar matters." As a part of the mandate, IRSDC seeks the participation of a private entity for the Redevelopment of Anand Vihar Railway Station including interalia all works related to, or incidental to, or required to be undertaken upon
2964-472: The above list has 23 of the 24 (Guyana missing). (↕) Identified on the European Union's first 2017 list of 17 tax havens; the above list contains 8 of the 17. (Δ) Identified on the first, and the largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); the above list contains 34 of the 35 (U.S. Virgin Islands missing). U.S. dedicated entities: Major sovereign States which feature on financial secrecy lists (e.g.
3040-489: The academic lexicon. Tax havens are typically small, well-governed states that impose low or zero tax rates on foreign investors. In April 1998, the OECD produced a definition of a tax haven, as meeting "three of four" criteria. It was produced as part of their "Harmful Tax Competition: An Emerging Global Issue" initiative. By 2000, when the OECD published their first list of tax havens, it included no OECD member countries as they were now all considered to have engaged in
3116-530: The accounting flows from BEPS tools are "out-of-proportion" and thus distort the economic statistics of the haven. The FSF–IMF list captured new corporate tax havens, such as the Netherlands, which Hines considered too small in 1994. In April 2007, the IMF used a more quantitative approach to generate a list of 22 major OFCs , and in 2018 listed the eight major OFCs who handle 85% of all flows. From about 2010, tax academics considered OFCs and tax havens to be synonymous terms . In October 2010, Hines published
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3192-614: The artificial debt-to-GDP). This can lead to severe credit cycles and/or property/banking crises when international capital flows are repriced. Ireland's Celtic Tiger , and the subsequent financial crisis in 2009–13, is an example. Jersey is another. Research shows § U.S. as the largest beneficiary , and use of tax havens by U.S corporates maximised U.S. exchequer receipts. Historical focus on combating tax havens (e.g. OECD– IMF projects) had been on common standards, transparency and data sharing. The rise of OECD-compliant corporate tax havens, whose BEPS tools were responsible for most of
3268-454: The case of British Empire–related tax havens, do not have a senior OECD member at their core. Some have suffered setbacks during various OECD initiatives to curb tax havens (e.g. Vanuatu and Samoa). However, others such as Taiwan (for AsiaPAC), and Mauritius (for Africa), have grown materially in the past decades. Taiwan has been described as "Switzerland of Asia", with a focus on secrecy. Although no Emerging market-related tax haven ranks in
3344-478: The consolidation treatment of these entities. There are a number of other standards that apply to different transactions with SPEs. Under International Financial Reporting Standards (IFRS), the relevant standard is IAS 27 in connection with the interpretation of SIC12 (Consolidation—Special-Purpose Entities). For periods beginning on or after 1 January 2013, IFRS 10 Consolidated Financial Statements supersedes IAS 27 and SIC 12. ^ a: For example, it
3420-563: The countries that received more than one US tax inversion since 1982 (see here ). In addition, six of these major tax havens are in the top 15 GDP-per-capita , and of the four others, three of them, the Caribbean locations, are not included in IMF-World Bank GDP-per-capita tables. In a June 2018 joint IMF report into the effect of BEPS flows on global economic data, eight of the above (excluding Switzerland and
3496-534: The developers. The various steps already taken and incorporated in the bidding document as corrigendum are as under: "Starting with five station, including two in Delhi, re-development and upgradation of railway stations across the country will be taken up under an agreement between Railway Land Development Authority (RLDA) with Indian Railway Station Development Corporation (IRSDC)." "The Chandigarh Administration on Thursday gave green signal to development plans of
3572-434: The development of Multi-Modal Transportation Hub (MMTH) along with Commercial Development on DBFOT-PPP mode was invited on 17 April 2018 so that in addition to the originally qualified developers, new Developers can also participate along with the already qualified Developers. After interaction with the probable bidders at GOG level, number of steps has been taken to make this unique project more attractive and risk free to
3648-590: The entity on whose behalf the SPE is being set up (the sponsor). For example, in the context of a loan securitization , if the SPE securitization vehicle were owned or controlled by the bank whose loans were to be secured, the SPE would be consolidated with the rest of the bank's group for regulatory, accounting, and bankruptcy purposes, which would defeat the point of the securitization. Therefore, many SPEs are set up as 'orphan' companies with their shares settled on charitable trust and with professional directors provided by an administration company to ensure that there
3724-463: The financial media, particularly when it lists the US and Germany as major "secrecy jurisdictions". However, many types of tax havens also rank as secrecy jurisdictions. While tax havens are diverse and varied, tax academics sometimes recognise three major "groupings" of tax havens when discussing the history of their development: As discussed in § History , the first recognized tax haven hub
3800-403: The five major global Conduit OFCs or any § Top 10 tax havens lists, both Taiwan and Mauritius rank in the top ten global Sink OFCs. Three main types of tax haven lists have been produced to date: Research also highlights proxy indicators , of which the two most prominent are: The post-2010 rise in quantitative techniques of identifying tax havens has resulted in a more stable list of
3876-476: The global flows to tax havens, with three of the five major global Conduit OFCs being European (i.e. the Netherlands, Switzerland, and Ireland). Four European-related tax havens appear in the various notable § Top 10 tax havens lists, namely: the Netherlands, Ireland, Switzerland, and Luxembourg. Many tax havens are former or current dependencies of the United Kingdom and still use the same core legal structures. Six British Empire–related tax havens appear in
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#17327914475283952-498: The haven has tax treaties; putting them on tax haven lists. According to modern studies, the § Top 10 tax havens include corporate-focused havens like the Netherlands, Singapore, Ireland, and the U.K., while Luxembourg, Hong Kong, the Cayman Islands, Bermuda, the British Virgin Islands, and Switzerland feature as both major traditional tax havens and major corporate tax havens. Corporate tax havens often serve as "conduits" to traditional tax havens. Use of tax havens results in
4028-532: The largest tax havens. Dharmapala notes that as corporate BEPS flows dominate tax haven activity, these are mostly corporate tax havens. Nine of the top ten tax havens in Gabriel Zucman 's June 2018 study also appear in the top ten lists of the two other quantitative studies since 2010. Four of the top five Conduit OFCs are represented; however, the UK only transformed its tax code in 2009–2012. All five of
4104-499: The lost taxes, led to criticism of this approach, versus actual taxes paid. Higher-tax jurisdictions, such as the United States and many member states of the European Union, departed from the OECD BEPS Project in 2017–18 to introduce anti-BEPS tax regimes, targeted raising net taxes paid by corporations in corporate tax havens (e.g. the U.S. Tax Cuts and Jobs Act of 2017 ("TCJA") GILTI–BEAT–FDII tax regimes and move to
4180-412: The master planning exercise shall be shared by IRSDC with the shortlisted bidders at the second stage i.e., RFP stage. The developer shall develop the entire project including the station redevelopment and commercial development on preferably DBFOT format. The developer shall be responsible for station facility operations during development/redevelopment and for a fixed period post construction. After this
4256-429: The parameters based on which it would select developers, and also explained the duties and responsibilities of developers. The developers have now been asked to send their suggestion by 15th January 2016 after which the railways would come out with a final document." Special purpose vehicle Normally a company will transfer assets to the SPE for management or use the SPE to finance a large project thereby achieving
4332-610: The past decade have substantially reduced the ability for individuals or corporations to use tax havens for tax evasion (illegal non-payment of taxes owed). These include the end of banking secrecy in many jurisdictions including Switzerland following the passing of the US Foreign Account Tax Compliance Act and the adoption of the CRS by most countries, including typical tax havens, a multilateral automatic taxpayer data exchange agreement, initiative of
4408-477: The performance of the new entity will not be affected by the ups and downs of the originating entity. The SPE will be subject to fewer risks and thus provide greater comfort to the lenders. What is important here is the distance between the sponsoring company and the SPE. In the absence of adequate distance between the sponsor and the new entity, the latter will not be an SPE but only a subsidiary company . A good SPE should be able to stand on its feet, independent of
4484-481: The planning of the redevelopment of the Surat MMTH: A truly seamless multi model transport hub integrating all modes of transport is to be developed at Surat Railway station wherein all the three levels of Government, namely Central Government (Railways), State Government (Gujarat State Road Transport Corporation) and local government (Surat Municipal Corporation) have come together to pool their lands and also form
4560-474: The project site in accordance with the provisions of the Development Agreement, and Applicable Laws, including the commercial development, redevelopment and station development, as required to be undertaken (the " Project ") on Design, Build, Finance, Operate and Transfer (the " DBFOT ") basis, and has decided to carry out the bidding process for selection of a private entity as the bidder to whom
4636-494: The provisions of all other Acts except the 'land acquisition' Act stand muted, in so far as the intent and purpose of the said clause is concerned. This legal position has been established has stood the "pith and substance" test of Constitutional scrutiny and validity in multiple cases ( Subhash Dutta vs. Union of India and Ors. 2001 , Goa Foundation and another vs. Konkan Railway Corporation 1992 , R. E. Marriott vs Municipality of Howrah, 1940 , The Municipal Corporation of Bombay vs
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#17327914475284712-420: The reform of its corporate tax code in 2009–2012, the UK has re-emerged as a major corporate-focused tax haven. Two of the five major global Conduit OFCs are from this grouping (i.e. the U.K. and Singapore). In November 2009, Michael Foot, a former Bank of England official and Bahamas bank inspector, delivered an integrated report on the three British Crown Dependencies (Guernsey, Isle of Man and Jersey), and
4788-482: The selection of the implementation agency has been issued by IRSDC for development of Bijwasan Station on DBFOT basis in accordance with the provisions of the development agreement, and local applicable Laws for commercial development, redevelopment and station development. Feasibility study and Master planning exercise has been carried out for development of Bijwasan railway station along with associated facilities and commercial development. Various approvals obtained during
4864-503: The six Overseas Territories (Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Turks and Caicos Islands), "to identify the opportunities and challenges as offshore financial centres", for the HM Treasury . As discussed in § History , most of these tax havens date from the late 1960s and effectively copied the structures and services of the above groups. Most of these tax havens are not OECD members, or in
4940-471: The sponsoring company. This does not always happen in practice. One of the reasons for the collapse of the Enron SPE was that it became a vehicle for furthering the ends of the parent company in violation of the prudential norms of corporate financing and accounting. Special-purpose entities were one of the main tools used by executives at Enron , in order to hide losses and fabricate earnings, resulting in
5016-399: The station operations shall revert to Indian Railways. The commercial area is envisaged to be operated by the developer for a concession period of 45 years (including construction period). Other stations that would come online in short order are as follows: On 16 November 2018, Press Information Bureau, Government of India reported the following in a press release about the decisions made on
5092-453: The stations under its management to the respective zonal railways . According to Section 11, Chapter 4, The Railways Act, 1989 , IRSDC has the authority to develop stations for the designated mandated purposes under its purview without requiring to seek approvals from local authorities. The aforementioned section has a non-obstante clause, a legislative device that precludes all extant laws and supersedes them. Therefore, by virtue of this Act,
5168-456: The tax revenues are needed to build infrastructure. Over 15% of countries are sometimes labelled tax havens. Tax havens are mostly successful and well-governed economies, and being a haven has brought prosperity. The top 10–15 GDP-per-capita countries, excluding oil and gas exporters, are tax havens. Because of § Inflated GDP-per-capita (due to accounting BEPS flows), havens are prone to over-leverage (international capital misprice
5244-501: The top 5 Sink OFCs are represented, although Jersey only appears in the Hines 2010 list. The studies capture the rise of Ireland and Singapore, both major regional headquarters for some of the largest BEPS tool users, Apple , Google and Facebook . In Q1 2015, Apple completed the largest BEPS action in history, when it shifted US$ 300 billion of IP to Ireland, which Nobel-prize economist Paul Krugman called " leprechaun economics ". In September 2018, using TCJA repatriation tax data,
5320-556: The tweets and the Facebook post that the RFQ submission date for Bijwasan had been postponed to 1 March 2016 upon the request of bidders. the response for this station was described as "huge". Bijwasan is an existing station on Delhi–Rewari line of Indian Railways network, proposed to be redeveloped as a world-class station in the National Capital Region of Delhi near Dwarka. The Request-for-Qualification document for
5396-448: The understanding of a tax haven into two classifications: In June 2018, tax academic Gabriel Zucman ( et alia ) published research that also ignored any definition of a tax haven, but estimated the corporate "profit shifting" (i.e. BEPS ), and "enhanced corporate profitability" that Hines and Dharmapala had noted. Zucman pointed out that the CORPNET research under-represented havens associated with US technology firms, like Ireland and
5472-445: The world's largest tax havens is therefore: Ireland, Singapore, Switzerland and the Netherlands (the major Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the major Sink OFCs), with the United Kingdom (a major Conduit OFC) still in transformation. Of these ten major havens, all except the United Kingdom and the Netherlands featured on the original Hines–Rice 1994 list . The United Kingdom
5548-400: Was claimed to be "excellent". It was further reported that the interested parties included corporations such as Shapoorji Pallonji, L&T, Tata group, GMR, IL&FS, Mcnally Bharat, Bharti Realty, Essel group, Ahluwalia, IRB Infra, Supreme Infrastructure, Oriental Structure, Bhartiya group, MBL Infrastructure, ASF Infrastructure, Bansal Constructions etc. Additionally, it was intimated through
5624-562: Was not a tax haven in 1994, and Hines estimated the Netherlands's effective tax rate in 1994 at over 20%. (Hines identified Ireland as having the lowest effective tax rate at 4%.) Four of these: Ireland, Singapore, Switzerland (3 of the 5 top Conduit OFCs), and Hong Kong (a top 5 Sink OFC), featured in the Hines–Rice 1994 list's 7 major tax havens subcategory; highlighting a lack of progress in curtailing tax havens. In terms of proxy indicators , this list, excluding Canada, contains all seven of
5700-484: Was the Zurich-Zug-Liechtenstein triangle created in the mid-1920s, later joined by Luxembourg in 1929. Privacy and secrecy were established as an important aspect of European tax havens. However, modern European tax havens also include corporate-focussed tax havens, which maintain higher levels of OECD transparency, such as the Netherlands and Ireland. European tax havens act as an important part of
5776-460: Was withdrawn after objections from the new U.S. Bush Administration in 2001, and in the OECD's 2002 report the definition became "two of three criteria". The 1998 OECD definition is most frequently invoked by the "OECD tax havens". However, that definition (as noted above) lost credibility when, in 2017, under its parameters, only Trinidad & Tobago qualified as a tax haven and has since been largely discounted by tax haven academics, including
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