Heads Up Hollywood

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 would only pay 20% - 35% of overseas income tax, instead of paying 20% ​​of American income tax.

Tang En handed over this task to Chief Financial Officer Brandy Norris.

Brandy Norris made a big trip to Europe, and finally came up with a detailed and shocking investigation report two months later!

"What did you say? Overseas income tax can also be exempted?" Tang En opened his eyes wide.

Brandy Norris said with a smile: "It is impossible to exempt all of them, but it can be greatly reduced. If it is done properly, it will be about... only need to pay 2.4% income tax."

Tang En was even more shocked, "2.4%? How is it possible?"

Brandy Norris said: "There are tax havens, you can register different offshore companies as subsidiaries, and then use these different subsidiaries to reverse accounts, transfer income to low-tax tax havens, and transfer expenses Go to countries and regions with high taxes. To put it bluntly, it is price shifting.”

"Price transfer?"

"Price shifting means that in order to achieve the purpose of reducing taxes, multinational companies use the tax systems of different jurisdictions to transfer resources in different jurisdictions through different departments within the company, such as the pricing between the parent company and its subsidiaries or between two overseas subsidiaries. transfer between subsidiaries."

Tang En took a deep look at Brandy, "Is this reliable? It won't be violated, right? The European Union has been eyeing American companies all the time."

Brandy Norris smiled slightly, "It's okay, this is the common tax operation method of multinational companies. And we have a big advantage, our products are intellectual property rights. Intellectual property rights are difficult to price, and there is no unified tax calculation formula in each country This can be applied, which allows us to take advantage of tax differences in different countries to achieve tax savings."

Tang En was a little confused. This kind of financial problem is the most complicated. He waved his hand, "Tell me, what should I do?"

Brandy Norris said: "First of all, establish a new global holding company in Ireland as the overseas headquarters of the new global group. Since the 1960s, Ireland has pursued the use of low tax rates to attract multinational companies, allowing the use of Ireland to transfer income , pay very little tax.”

"Multinational companies accumulate profits in Ireland, and then easily remit the profits to Bermuda. Once the non-US profits of multinational companies enter Bermuda, it will be difficult for US regulatory authorities to track. According to Irish law, subsidiaries established there do not need to report Financial information including any income statement or balance sheet."

"Then, set up a new global subsidiary in Germany, which is mainly responsible for business processing, and pay intellectual property rights through this subsidiary. tax on what I call the 'double hamburger' structure."

"Through this 'Irish-German double hamburger' structure, the overseas income tax can be reduced to 12.5%. This is not enough. Since the exemption of withholding tax in the Irish tax law is only for EU member companies, the new Universal is not part of the EU. To avoid withholding tax in Ireland, payments from the German subsidiary do not go directly to Bermuda, but bypass a shell company in the Netherlands with no employees.”

"The Netherlands has a loose tax policy. The Dutch shell company will transfer about 99.8% of the royalties to Bermuda. Through the Irish headquarters that holds intellectual property rights, the German subsidiary that is responsible for business processing, and the Dutch subsidiary that is empty, you can Easy tax avoidance. I call it a 'Dutch sandwich' structure."

Tang En watched Brandy Norris talking eloquently and felt his confidence. He also felt dizzy and dizzy for a while. All he knows is that the head office in Ireland is responsible for selling intellectual property rights, the subsidiary in Germany is responsible for specific business processing, the subsidiary in the Netherlands is Airbus, and the subsidiary in Bermuda is completely stranded to avoid the supervision of the US Department of Justice. up.

Tang En coughed lightly, "To make a long story short, just say how much tax can we avoid?"

Brandy Norris said: "Through this operation, 88% of the German company's operating profits can be transferred to tax havens, and only the remaining 12% of profits can be paid for income tax. On average... our overseas Income, only need to pay 2.4% income tax. Based on the revenue of the New Universal Group this year, if we use this structure, this year... can save at least 1.5 billion US dollars in tax expenses!"

"$1.5 billion!"

Tang En took a deep breath, "Okay! Brandy, you go and talk to Barry about this matter, let's do it like this, and start this 'burger' and 'sandwich' plan immediately. Next year, the reorganization of the New Universal Group will be completed." It's over, our overseas income must have reasonable means of tax avoidance!"

"no problem!"

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

Brandy Norris is not only the person in charge of overseas headquarters planning, but also the chief financial officer of New Universal Group. Barry Diller must communicate with him if he wants to sell the USA TV network.

"It's hard!" Brandy Norris was cautious. "The USA TV network has changed hands twice within a year, which has caused instability. It's hard for a company to take over. Especially now that Viacom's targeted With such strength, the prospect of the USA TV network is not optimistic. The top priority is that we are not rushing to sell the USA TV network, but to find a way to keep the USA TV network alive under Viacom’s suppression.”

"well said!"

Tang En sighed in admiration.

On this matter, Dunn and Barry Diller had some disagreements. The latter believes that it should be sold immediately, even if the price is lower, and the burden of the USA TV network should be thrown off, and more energy should be devoted to potential businesses.

Barry Diller has cooperated with Jack Welch for many years, and he is deeply influenced by his "number one or number two" principle, that is, if this business has no possibility of becoming the number one or number two in the industry, it must be abandoned immediately. Do not hesitate!

But Tang En didn't want to make a loss-making business.

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, but it's just a little troublesome.

He is prescient.

After these few years have passed and Viacom is brought down, the spring of the USA TV network will come.

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

...

Just like the general opinion in the industry.

The USA TV network, under the targeting of the MTV TV network, has no possibility of resistance. In just one week, the USA TV network lost more than 300,000 home users.

Barry Diller was a little impatient, "Twain, I think Comcast's offer of US$3.2 billion can be accepted to sell USA Television Network!"

Tang En laughed angrily, "3.2 billion US dollars? Barry, don't you think this is an insulting offer? Comcast is singing a double reed with Viacom!"

Last year, Vivendi bought the USA Television Network for US$10.3 billion. This year, the USA Television Network was sold to Twain for US$4.5 billion.

In this transaction, Vivendi made the whole world laugh.

Just two months later, Tang En was going to sell USA TV Network for 3.2 billion dollars?

Doesn't New Universal equate with Vivendi? Became a laughing stock?

Barry Diller frowned, "Twain, we are businessmen, we can't act emotionally, the USA TV network is in a big crisis right now!"

Tang En didn't think so, and sneered, "Comcast wants to make a profit. It's a dream! Even if the USA TV network is rotten in my hands, I can't sell it to Comcast at a low price! Unless, they can offer 50 One hundred million U.S. dollars!"

Barry Diller's face was a little ugly.

$5 billion?

It's just a fantasy.

The entire United States knows that the USA TV network has become a thorn in Redstone's side. At this time, Comcast is willing to buy it, which is already very good.

It would be impossible for another company to spend more than $3 billion to buy a risky cable network.

"Barry, Jeff Zucker was able to jump ship to take over the TV Media Department because I gave him a guarantee. I promised him that the New Global Group will focus on developing the TV Media Department in the next few years. I can't break my promise, right? He just joined , I sold the USA TV network, and I can't explain to him."

Tang Enyu said earnestly.

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

Tang En shook his head and said, "Maybe he has enough professionalism, but I can't break my promise and get rich. Besides, the USA TV network...is not really hopeless, as long as it is operated properly, it can be completely bright!"

"oh?"

Barry Diller's eyes lit up.

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

However, he also knew about some secret operations that Tang En had in private.

"You mean American Idol?"

"Hey, Redstone wants to play, so I'll play with him! Anyway, the second season of "American Idol" is no longer run by CBS!"

Barry Diller narrowed his eyes, "Viacom's stock price has declined this year. On the one hand, it is because the competition with Disney has intensified. Concerned. If we announced at this time that American Idol would no longer be partnering with CBS for a second season..."

Tang En 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 heavy weapon, I can't give it to Disney for nothing."

"You mean...USA Television Network?"

"That's right!"

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

Twain's relationship with Time Warner was average, but his relationship with Disney was complicated.

usable!