Conduit and Sink OFCs: How the Netherlands and Ireland Route Offshore Money

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An offshore financial center, by the IMF's definition, is about who uses it, not where it sits: a jurisdiction serving non-residents on a scale far out of proportion to its own economy. In the 1960s and 1970s these centers held pools of eurodollars that escaped capital controls; once controls faded in the 1980s, they shifted to selling tax neutrality, levying no tax on funds passing through on the theory that investors pay at home. The University of Amsterdam's CORPNET study mapped 98 million corporate ownership connections and found 24 sink centers, such as the Cayman Islands, British Virgin Islands and Bermuda, where value comes to rest, and five conduits that route it there: the Netherlands, the United Kingdom, Switzerland, Singapore and Ireland.

Conduits matter because of their tax treaty networks, letting money move from a country like Germany to the Netherlands and then to Bermuda without withholding taxes. The episode walks through an Irish Section 110 special purpose vehicle that borrows from Deutsche Bank, buys Boeing engines and leases them to Delta, protected by orphan status and bankruptcy remoteness. Economist Gabriel Zucman puts annual corporate tax losses from profit shifting at over $200 billion, and Apple's double Irish structure moved $300 billion in intellectual property in 2015 before the EU levied a record $13 billion state aid ruling. Economist James R. Hines Jr. argues these centers help high-tax countries by easing cross-border investment.

• Shadow banking assets in the Cayman Islands were measured at 2,118 times GDP, versus 246 times in Luxembourg.
• Ireland's ratio is 13 times GDP and the Netherlands nearly nine times.
• In the double Irish, one Irish company was managed from Bermuda and collected royalties from a second Irish company.
• Anonymous shell companies are often easier to form in Delaware or Nevada than in the Cayman Islands.
• Verified ownership registers in some centers helped authorities trace and freeze Russian oligarch assets under sanctions.