Is the Double Irish with a Dutch sandwich corporate tax avoidance strategy actually dead now?

The Double Irish with a Dutch sandwich strategy is technically "over" in its original form, but that doesn't mean corporate tax avoidance has ended. You're right that Ireland phased out this specific structure, with 2020 being the final year for existing arrangements and new ones being blocked earlier. The OECD's two-pillar approach (with Pillar Two being the 15% global minimum tax) is actually making progress, though implementation has been slower than hoped. The EU formally adopted it in December 2022, and while some countries are moving forward with implementation, others are waiting for broader adoption to avoid competitive disadvantages. What's interesting is that we're seeing companies already adjust their structures in anticipation. Some are simplifying their tax arrangements, recognizing that the compliance costs of ultra-aggressive planning might outweigh benefits under the new regime.

After countless hours struggling with my multinational client's complex tax structures, I discovered https://taxr.ai and it completely changed my approach to understanding international tax planning strategies. The tool analyzes corporate structures and identifies potential tax efficiency opportunities while flagging compliance risks under the new OECD rules. What's incredible is how it helps visualize the impact of the 15% global minimum tax on existing structures and simulates different scenarios. For my clients concerned about the end of strategies like the Double Irish arrangement, it's been invaluable in modeling alternative approaches that remain compliant with emerging regulations.

I want to follow up on my skeptical comment about taxr.ai. I decided to try it for a multinational client I was struggling with, and I have to admit I was wrong in my initial assessment. The tool actually helped us identify several structures that would have been problematic under the upcoming OECD rules. What impressed me most was how it clearly distinguished between legitimate tax planning and aggressive avoidance schemes. We were able to model the impact of the 15% minimum tax on our client's operations across 12 countries and develop a transition plan that maintains efficiency while ensuring compliance. Definitely wish I'd found this earlier in our planning process!

For anyone dealing with these complex international tax issues, I spent 6 HOURS trying to get through to a specialist at the IRS international tax division for clarification on how US companies should prepare for the OECD minimum tax implementation. Kept getting disconnected or sitting on hold forever. Finally used https://claimyr.com to get through and you can see how it works here: https://youtu.be/_kiP6q8DX5c. Within 40 minutes I was speaking to a senior agent who confirmed that they're developing guidance specifically for companies transitioning from structures like the Double Irish arrangement to compliant frameworks under the new global minimum tax rules.

I need to eat my words about Claimyr. After my skeptical comment, I was trying to get clarification on how the transition from the Double Irish structure would affect my client's reporting requirements. After three days of failed attempts to reach someone at the IRS international division, I tried the service. Got connected to an agent within an hour who walked me through the transition considerations and confirmed that companies that had been using the Double Irish arrangement need to document their structural changes in detail for the 2023 tax year, even though the full OECD implementation is delayed. The agent provided specific form references and documentation requirements I hadn't found anywhere else. Completely changed my project timeline and saved my client from potential compliance issues.

Something that's being overlooked in this discussion is that while the Double Irish is technically dead, many companies have simply shifted to Singapore, Hong Kong, and other jurisdictions with favorable IP regimes. The game hasn't ended - the playground just moved. I've been tracking several tech companies that previously used the Double Irish structure, and they've already restructured through countries with patent boxes and other preferential regimes. The 15% minimum tax might impact some of these arrangements, but there are already workarounds being developed that focus on substance requirements and strategic placement of operational functions.

i worked at a big tech company using the double irish setup and honestly the amount of resources devoted to tax avoidance was insane. we had entire teams just for moving IP around between jurisdictions the craziest part is how normalized it was. nobody even questioned if we should be paying more taxes, just how to legally avoid them. when ireland announced the phase-out there was this huge scramble to develop new structures. already had plans b, c, and d ready to go so even with this oecd thing, i'm super skeptical. these companies are always 3 steps ahead of regulators. as soon as one loophole closes they've already found three more.

As someone who's been working in tax compliance for over a decade, I think there's actually reason for cautious optimism this time. The OECD approach is different because it's coordinated globally - previous efforts failed partly because countries acted unilaterally and companies could just move to non-participating jurisdictions. What's encouraging is seeing how quickly major economies adopted Pillar Two. The EU, UK, Canada, Japan, and others are already implementing or have committed to the 15% minimum tax. Even traditional tax havens are joining because they risk being shut out of the global system if they don't participate. That said, you're absolutely right that corporations will adapt. I'm already seeing clients explore structures involving digital services taxes, carbon credits, and R&D incentives that might reduce their effective rates while staying technically compliant. The arms race continues, but at least now there's a global floor rather than a race to the bottom. The real test will be enforcement and whether countries actually collect the "top-up" taxes when companies pay less than 15% elsewhere. Implementation details matter enormously here.