CitiXsys is a tech company founded by an Indian entrepreneur, Kamal Karmakar, in 2006. The company develops software solutions for the distribution and retail supply chain markets. Its principal product is the iVend Retail, which is a retail management software solution. It also develops a range of business management applications integrated with the SAP suite. CitiXsys has a number of strategic alliances with SAP, including in the US and the UK. The company is based in New York with several offices and R&D centres around the world, including Dublin. The Papers highlight CitiXsys as one of the companies who recently exploited the notorious double-Irish tax structure.
The double-Irish tax structure in question was first established in the late 1980s. It exploited the lack of transfer pricing rules in Ireland to move profits in a …show more content…
The Papers reveal emails from DLP Piper, the company’s law firm in San Francisco, in November to the Appleby offshore law firm, in the Isle of Man, outlining the group’s aim to establish a double Irish tax structure before 2015. The company quickly created two Irish companies with Dublin addresses, which were incorporated on the 8th of December 2014, 3 weeks before Michael Noonan’s window closed on the controversial structure. One of the companies is tax resident in the Isle of Man and it had its first board meeting just a week later in the offices of the offshore law firm. The Papers clearly reveal that CitiXsys created the two Irish companies solely for tax reasons. Lawyers referenced the closure of the window of opportunity at the end of 2014 and documents state that the group could ‘benefit from a single digit effective tax rate on non-US revenues through to calendar year 2020’. Investigators estimate that CitiXsys could achieve an effective tax rate between 5 and 7 per cent, almost a full 10% lower than the company’s effective tax rate in 2014 of
The double-Irish tax structure in question was first established in the late 1980s. It exploited the lack of transfer pricing rules in Ireland to move profits in a …show more content…
The Papers reveal emails from DLP Piper, the company’s law firm in San Francisco, in November to the Appleby offshore law firm, in the Isle of Man, outlining the group’s aim to establish a double Irish tax structure before 2015. The company quickly created two Irish companies with Dublin addresses, which were incorporated on the 8th of December 2014, 3 weeks before Michael Noonan’s window closed on the controversial structure. One of the companies is tax resident in the Isle of Man and it had its first board meeting just a week later in the offices of the offshore law firm. The Papers clearly reveal that CitiXsys created the two Irish companies solely for tax reasons. Lawyers referenced the closure of the window of opportunity at the end of 2014 and documents state that the group could ‘benefit from a single digit effective tax rate on non-US revenues through to calendar year 2020’. Investigators estimate that CitiXsys could achieve an effective tax rate between 5 and 7 per cent, almost a full 10% lower than the company’s effective tax rate in 2014 of