Thursday, July 9, 2015
H202B (28 rue des Saints-Pères)
A sponsored editorial in the trade magazine Airfinance Journal, “Best of both Worlds – Cayman Incorporated, Irish tax Resident” presents a persuasive case for tax planning for aircraft leasing that would involve at least the two jurisdictions, Cayman Islands and Ireland. The different entities of such tax schemes may present themselves as separate and unconnected, and indeed, when seen in isolation may not appear particularly abusive. It is only when combined through complex ownership structures, that the true purpose of the scheme is revealed. My paper discusses how Caribbean jurisdictions develop a sophisticated regulatory environment that aims to capture such hybrid structures.