FROM GOOGLE'S "DOUBLE IRISH" TO NEW SOLUTIONS: AN INTERNATIONAL TAX AVOIDANCE FRAMEWORK

In today’s global economy, characterized by intra-group transactions, multinational enterprises play a significant role in international trade, and in the flow of labour and capital. However, their ability to exploit regulatory mismatches across the different jurisdictions in which they operate has created concerns about tax avoidance, artificial base erosion and profit shifting practices. The digitalization of the economy has amplified these practices, challenged the effectiveness of existing tax systems by raising problems about transparency, fairness, and the sustainability. This thesis, entitled From Google’s “Double Irish” to New Solutions: An International Tax Avoidance Framework, analyses the relationship between globalization, multinational corporations, and the regulatory framework of international taxation and the instruments employed by multinational corporations. It explores the methods of transfer pricing mechanism, the OECD’s Base Erosion and Profit Shifting (BEPS) project, and reforms such as the Global Minimum Tax (Pillar Two) and the regulations proposed by the European Union. The work also explores the practical case of Google’s use of the “Double Irish with a Dutch Sandwich” mechanism and, it examines new solutions, such as the Digital Services Tax, the comparison with the Global Minimum Tax, and the application of blockchain technology to increase tax transparency. 3 This research tries to answer three main questions: • How do multinational enterprises exploit transfer pricing, intangible assets, and digitalization to implement aggressive tax planning strategies? • What are the implications of the OECD and EU regulations for the future of international corporate taxation? • Is it possible to build a transparent and sustainable international tax system without a shared global consensus? The final purpose of this work is to combine theoretical aspects with the study of a practical case, offering an overview of the opportunities and limitations of current and future tax policies and, integrating them with emerging technologies, like blockchain, better suited to the digital economy. Keywords: Multinational Enterprises, Multinational Corporations, Globalization, Transfer Pricing, Arm’s Length Principle, Base Erosion and Profit Shifting (BEPS), Tax Havens, OECD Guidelines, Global Minimum Tax, EU Regulations, Digital Services Tax, Blockchain Technology, International Taxation, International Cooperation.