Two weeks after Twitter filed the paperwork for a planned billion-dollar IPO, we learn that it's poised to take advantage of the same international tax loopholes as other large firms like Apple, Google, and Amazon. Citing Twitter Ireland documents, Valleywag reports that the company has all the requisite parts for the "Double Irish and Dutch Sandwich" — a scheme that can minimize a company’s tax exposure by enabling it to lease its intellectual property to foreign subsidiaries. The idea is to turn foreign profits into tax-free revenues, and everything from the existence of Irish shell companies to their Cayman Islands home base give ample insight into Twitter’s strategy.
It makes sense that [Twitter has] the structure in place up front
Valleywag quotes a corporate tax attorney who stressed the idea of getting the plan in place early. "The key to these structures is that you have to set them up when you are creating the [intellectual property]… it makes sense that [Twitter has] the structure in place up front," they explained.
Of course, there are a few things standing in the way of it taking its plan into action. First, Twitter isn’t yet profitable — it actually lost nearly $70 million in the first six months of 2013. But even more to the point, Ireland’s Finance Department is mulling the idea of closing the loophole altogether. The proposal wouldn’t take place until 2015, but finance minister Michael Noonan sounds convinced that it’s the right course of action, saying that he would submit "a change to ensure that Irish registered companies cannot be ‘stateless’ in terms of their place of tax residency."