More than half of the profits made by U.S. companies abroad are still recorded in only a few low-tax havens — places that, of course, are not home to the customers, workers, and taxpayers who facilitate most of their business. A multinational can channel its global turnover via Ireland, pay royalties to its Dutch subsidiary, and then channel its revenues to its Bermuda subsidiary, taking advantage of Bermuda`s zero corporate tax rate. A tax haven or «offshore financial center» is a country (or state) where foreign investors pay taxes at an unusually low or no rate. By transferring their funds to or through tax havens, companies and other investors can avoid paying taxes in high-tax countries. Residence or commercial presence is generally not required to benefit from the policies of a tax haven (although it may be in tax-exempt countries). In addition, tax havens share little or no financial information of their investors with foreign tax authorities. Therefore, the data (although undoubtedly limited) do not indicate the impact of the OECD initiative on activity in tax havens. [..] Therefore, the OECD initiative is not expected to have a major impact on the use of tax havens by companies, even if (or if) the initiative is fully implemented (*) is included in all three lists as one of the ten largest tax havens; 9 major tax havens meet this criterion: Ireland, Singapore, Switzerland and the Netherlands (bridge CFOs) as well as the Cayman Islands, the British Virgin Islands, Luxembourg, Hong Kong and Bermuda (CFO Sinks). (†) Also appears as one of the 5 OFC Conduit (Ireland, Singapore, Switzerland, Netherlands and UK) in the 2017 CORPNET study; or (‡) is also included in the Top 5 OFC wells (British Virgin Islands, Luxembourg, Hong Kong, Jersey, Bermuda), in the CORPNET 2017 study.
(Δ) Identified on the first and largest OECD list of 2000 with 35 tax havens (the OECD list included only Trinidad and Tobago in 2017).   Bankers are prohibited from sharing client information with applicants. For many years, many companies and individuals from all over the world have benefited from Switzerland`s tax advantages. As of October 2021, 11.9 million leaked documents containing 2.9 terabytes of data were leaked by the International Consortium of Investigative Journalists (ICIJ). The leak revealed the secret offshore accounts of 35 world leaders, including current and former presidents, prime ministers and heads of state, as well as more than 100 billionaires, celebrities and business leaders. U.S. multinationals make more use of tax havens[i] than multinationals in other countries that have maintained their regulations on controlled foreign corporations. No other OECD country has as high a share of foreign profits in tax havens as the United States.[…] This suggests that half of all global profits transferred to tax havens are transferred by US multinationals. In contrast, around 25% are represented by EU countries, 10% by the rest of the OECD and 15% by developing countries (Tørsløv et al., 2018). Here are some of the world`s leading tax havens: Double Irish was the largest BEPS tool in history, protecting more than $100 billion in profits of predominantly U.S. corporations from U.S. tax in 2015. When the European Commission fined Apple €13 billion for using an illegal Irish hybrid dual structure, its report revealed that Apple had been using the structure since at least 1991.  Several Senate and congressional surveys in Washington have cited public knowledge of the Irish Dual from 2000 onwards. However, it was not the United States that finally forced Ireland to close the structure in 2015, but the European Commission;  and existing users had until 2020 to find alternative arrangements, two of which (e.g. a single malt arrangement) were already in effect.   The U.S. inaction, similar to its position vis-à-vis the OECD MLI (above), has been attributed to the U.S. as the largest user and beneficiary of tax havens.
However, some commentators point out that the fundamental reform of U.S. corporate tax law by the TCJA 2017 could change that.  The Netherlands is one of the most popular tax havens, especially for Fortune 500 companies. While about a quarter of these companies use Bermuda, more than half of Fortune 500 companies use the Netherlands as a tax haven. A tax haven is a jurisdiction where «effective» tax rates for foreign investors are very low (overall rates may be higher). [a]      In some traditional definitions, a tax haven also provides financial secrecy. [b]  Although countries with a high level of secrecy but also high tax rates, in particular the United States and Germany in the Financial Secrecy Index («FSI»)[c], may be included in some lists of tax havens, they are generally not considered tax havens. On the other hand, countries where secrecy is lower but also low «effective» tax rates, especially Ireland in the ISF ranking, appear in most lists of tax havens §.  The consensus on effective tax rates has led academics to conclude that the terms «tax haven» and «offshore financial centre» are almost synonymous.  Hines and Dharmapala concluded that governance is an important issue for small countries trying to become tax havens.
Only countries with strong governance and legislation, trusted by foreign companies and investors, would become tax havens.  Hines and Dharmapala`s positive view of the financial benefits of becoming a tax haven, as well as two of the most important academic leaders in tax haven research, brought them into conflict with tax justice NGOs, such as the Tax Justice Network, which accused them of encouraging tax evasion.    Bermuda`s focus on privacy for aspiring bankers is among the best in the world.