The Globe and Mail reports in its Thursday edition Fairfax Financial, Brookfield Asset Management and Yamana Gold are among several high-profile companies whose tax arrangements in Luxembourg have been leaked as governments fret about corporate tax strategies.
The Globe's Bertrand Marotte and Jeff Gray write a new batch of leaked documents released late Tuesday by the Washington-based International Consortium of Investigative Journalists provides a glimpse into the complex structures used by many global corporate giants to move profits into subsidiaries in Luxembourg, one of several tax havens around the world.
Essentially, these types of dealings use so-called "hybrid mismatch arrangements" to play off different tax regimes in different countries in order to end up with a low or zero tax bill, said Laval University tax law professor Andre Lareau.
One of the schemes used is where a company appears to transfer funds to a Luxembourg-based subsidiary in exchange for mandatory redeemable preferred shares, which are treated as debt. All payments made by the Luxembourg company are treated as interest payments.
Cash going back to the Canadian parent is in the form of dividends, which are not taxed.
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