In order to avoid "double taxation" in the United States, Tang En decided to establish a new global overseas headquarters, so that the company's overseas income will only pay 20%-35% of the overseas income tax, and no longer pursue the 20% of the US income tax.

This task was given to Chief Financial Officer Brandi Norris.

Brandi Norris went around Europe and finally came up with a detailed, shocking investigation report two months later!

"What do you mean, overseas income tax can also be exempted?" Donne's eyes widened.

Brandi Norris laughed, "It's impossible to get rid of them all, but it can be greatly reduced, and if done properly, it can be about ...... You only need to pay 2.4% income tax. ”

Don was even more shocked, "2.4%?

Brandi Norris said: "There are tax havens, you can register different offshore companies, act as subsidiaries, and then use these different subsidiaries to reverse the accounts between them, transfer income to low-tax havens, and transfer expenses to high-tax countries and regions." To put it bluntly, it is a price transfer. ”

"Price transfer?"

"Price transfer refers to the transfer of resources between subsidiaries in different jurisdictions by multinational corporations in order to achieve the purpose of reducing taxes, with the help of the tax system of different jurisdictions, through different departments within the company, such as the parent company and the subsidiary or between two overseas subsidiaries. ”

Don gave Brandi a deep look, "Is this reliable? It won't be illegal, right? The European Union has been eyeing American companies." ”

Brandi Norris smiled slightly, "It's okay, this is the common way of tax operations for multinational companies. And we also have a big advantage, our products are intellectual property. Intellectual property is difficult to price, and there is no unified tax formula for each country to apply this, which allows us to take advantage of the tax differences in different countries to achieve the purpose of tax savings. ”

Tang En was a little confused when he heard it, this kind of financial problem is the most complicated, and he waved his hand, "Tell me, what should I do?"

Brandi Norris said: "First, establish a New Globe Holdings company in Ireland to serve as the overseas headquarters of the New Globe Group. Since the 60s, Ireland has pursued a low tax rate to attract multinational corporations, allowing the use of Irish transfers of income and paying very little taxes. ”

"MNCs accumulate profits in Ireland and then easily remit them to Bermuda, which is very difficult for US regulators to track once the non-US profits of the MNC come into Bermuda. Under Irish law, a subsidiary established where it is established is not required to report any financial information including an income statement or balance sheet. ”

"Then, a new global subsidiary was set up in Germany, which was mainly responsible for business processing, and through this subsidiary, the intellectual property royalties were paid, and the expenses were reduced in the taxes payable in Ireland, and the Irish headquarters company was in the tax haven of Bermuda to collect licensing fees to avoid taxes in Ireland, which I call a 'two-tier burger' structure. ”

"Through this 'Irish-German double-tier hamburg' structure, the overseas income tax can be reduced to 12.5%. This is not enough. As the exemption from withholding tax under the Irish tax law only applies to companies in EU member states, New Globe does not belong to the EU. To circumvent Ireland's withholding tax, the German subsidiary's payments were not made directly to Bermuda, but instead bypassed to a shell company with no employees in the Netherlands. ”

"The Netherlands has a liberal tax policy, and the Dutch shell company will transfer about 99.8% of the royalties to Bermuda, which can easily be avoided through the Irish headquarters that owns the intellectual property, the German subsidiary that is responsible for business processing, and the Dutch subsidiary of the shell. I call it the 'Dutch sandwich' structure. ”

Don watched Brandi Norris talk eloquently, feeling his confidence, but also a big head and dizzy. He only knew that the head office in Ireland was responsible for selling intellectual property rights, the German subsidiary was responsible for specific business processing, the Dutch subsidiary was Airbus, and the Bermuda subsidiary was completely stranded in funds and evaded the supervision of the US Department of Justice.

Don coughed lightly, "Long story short, how much tax can we avoid?"

Brandi Norris said: "Through this operation, 88% of the operating profits of German companies can be transferred to tax havens, and only the remaining 12% of profits can be paid income tax, which is averaged...... Our overseas income is only subject to 2.4% income tax. In terms of New Globe's revenue this year, if we use this structure, this year will be ...... At least $1.5 billion in tax savings!"

"$1.5 billion!"

Don took a deep breath, "Okay, Brandy, you go and talk to Barry about this, that's it, and start this 'burger' and 'sandwich' plan right away." Next year, the restructuring of New Global Group will come to an end, and our overseas income must have reasonable tax avoidance methods!"

"No problem!"

"Well, by the way, you know about the USA Network, right?"

Brandi Norris is not only the head of planning for the overseas headquarters, but also the chief financial officer of the New Globe Group, and Barry Diller must communicate with him if he wants to sell the USA television network.

"It's hard!" Brandi Norris is cautious, "the USA network has changed hands twice in a year, and it's already caused instability, and it's hard for a company to want to take over." Especially now that Viacom is so targeted, the future of the USA television network is not optimistic. The top priority is not to rush to the USA network, but to find a way to keep the USA network alive under the pressure of Viacom. ”

"Well said!"

Don sighed in admiration.

On this matter, Donn and Barry Diller had some disagreements. The latter believes that it should be done immediately, even if the price is lower, and it is necessary to get rid of the burden of the USA TV network and devote more energy to the potential business.

Barry Diller and Jack Welch have been working together for many years and are deeply influenced by his "one of the best" principle, which means that if this business does not have the possibility of becoming the first or second in the industry, it must be abandoned immediately and without hesitation!

But Donn didn't want to trade at a loss.

It's not that the USA TV network can't be sold, but it can't be sold at a low price, it's not that it can't be saved, it's just a little troublesome.

He was prescient.

After a few years of slowing down and bringing down Viacom, the spring of the USA television network will come.

At that time, whether the USA TV network is sold or restructured can be decided by itself.

……

It's the same as the general perception in the industry.

The USA television network, under the targeting of the MTV television network, had no possibility of resistance, and in just one week, the American television network lost more than 300,000 home subscribers.

Barry Diller was a little impatient, "Donn, I think it's okay to accept Comcast's $3.2 billion offer to sell USA Network!"

Don laughed angrily, "$3.2 billion, Barry, don't you think it's an insulting offer? Comcast is singing a duet with Viacom!"

Last year, Vivendi bought USA for $10.3 billion, and this year, USA sold to Donn for another $4.5 billion.

In this deal, Vivendi made the whole world laugh.

Just two months later, Donn is going to sell the USA network for $3.2 billion?

Isn't New Universal equating with Vivendi?

Barry Diller frowned, "Don, we are businessmen, we can't be emotional, USA TV Network is in a big crisis right now!"

Don didn't think so, and sneered: "Comcast wants to make a profit from the fisherman, it's a dream! Even if the USA TV network rots in my hands, I can't sell it to Comcast at a low price! Unless, they can offer $5 billion!"

Barry Diller's face was a little ugly.

$5 billion?

It's a fantasy.

The whole United States knows that the USA TV network has become a thorn in Lei Shidong's side, and at this time, Comcast is willing to buy it, which is already very good.

It would be impossible to spend more than $3 billion on a risky cable network.

"Barry, Jeff Zucker was able to jump ship and take over the TV media department because I gave him a promise that he would focus on the development of the TV media department in the next few years. I can't break my promise, right? He just joined, and I sold the USA network, and I can't explain it to him. ”

Don said earnestly.

Barry Diller said lightly: "He is a businessman, he has a qualified business mind, and he can understand the group's decision-making. ”

Don shook his head and said, "Maybe he has enough professionalism, but I can't break my word." Besides, USA Network...... It's not really hopeless, as long as you do it properly, you can see it!"

"Oh?"

Barry Diller's eyes lit up.

Because of his complicated relationship with Michael Eisner, the cooperation between New Universal and Disney is currently in charge of Donn.

However, he also knew about some of Don's secret operations in private.

"You mean American Idol?"

"Hmph, Lei Shidong wants to play, I'll play with him! In any case, the second season of "American Idol" can no longer be operated by CBS!"

Barry Diller's eyes narrowed, "Viacom's stock price this year is very sluggish, on the one hand, because of the intensifying competition with Disney, and on the other hand, the contradictions between Lei Shidong and Mayer Kamasin make investors worried. If we announce at this time that the second season of "American Idol" will no longer work with CBS......"

Donn waved his hand, "Don't worry! I've already made an appointment with Michael Eisner, I'll talk to him first! "American Idol" is a blockbuster weapon, I can't give it to Disney for nothing. ”

"You mean...... USA Television Network?"

"That's right!"

The USA television network, which is targeted by the MTV television network, has been severely squeezed in its living space. If you want to survive in this situation, if you look at cable networks across the United States, it is estimated that only CNN and ESPN can solve it.

Don and Time Warner have an average relationship, but their relationship with Disney is complicated.

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