The Named Tax Structures, Explained: Double Irish, Dutch Sandwich, Single Malt and the Rest

The short version: these are the named structures big companies have used to move profit out of reach of the taxman. Most are legal. Several have since been closed. We explain how each one works, step by step, who could use it, and whether it still can.

None of it is illegal where noted. It's the rules working as written. The companies followed them. Governments wrote them.

A "tax structure" is not a trick and it is not fraud. It is an arrangement of companies, contracts and the gaps between two countries' rule books, set up so that profit lands where the tax is lowest. Each one has a name because lawyers and journalists needed a shorthand for the same recurring shape: a parent here, an operating company there, a holding company somewhere with no tax at all, and a chain of payments running between them.

The mechanism is almost always the same idea in different clothes. A company earns money in a place with normal tax rates. It then pays that money out again, as a royalty for using a brand, or as interest on a loan, or as a licence fee for some patents, to a related company in a place with little or no tax. The first payment is a cost, so it reduces the taxable profit in the high-tax country. The receipt is barely taxed in the low-tax one. The profit has not gone anywhere in real terms. On paper it has moved.

What makes these structures work is rarely a single loophole. It is a mismatch. One country says a company is resident where it is run; another says it is resident where it was registered. One country treats a partnership as a separate taxpayer; another treats it as invisible. Slot a company into the seam between two such rules and it can end up taxed by neither. That is the engine under most of the names below.

Almost all of this was legal where it was used. That is the uncomfortable part. The companies did not break the law. They read it carefully and followed it precisely. The rules were written by governments, lobbied over by industry, and left in place for years after everyone understood what they did. When a structure closes, it closes because a government finally rewrote the rule, not because anyone was caught.

Below is the encyclopedia. Each entry covers what the structure is, how it works step by step, who is on the public record as having used it, and whether it is still open or closed, and when. The dates matter, because several of these are dead and you will still see them described as live.

The index

• The Double Irish. The most famous of them all. A residency mismatch plus a US tax election that let profit pool, untaxed, in Bermuda. Closed to new entrants 2015, fully phased out end of 2020.
• The Dutch Sandwich. Not a structure on its own, but the Dutch layer slotted into the Double Irish to strip out a withholding tax on the way through. Closed from 2021.
• The Single Malt. The Double Irish's successor, swapping Bermuda for Malta through a treaty gap. Closed by Ireland and Malta on 27 November 2018.
• The Green Jersey. Ireland's reply to losing the Double Irish: keep the profit in Ireland but wipe out the tax with a capital allowance on intangible assets. Still on the statute book.
• The CV/BV. A Dutch hybrid that fell into the gap between Dutch and US law and was taxed by neither. Closed in stages, finished off on 1 January 2025.
• Corporate inversions. A US company merges with a smaller foreign one and adopts its home as the new tax address. Heavily restricted since 2004, then largely defused by the 2017 US tax cut.
• The Killer B. A triangular reshuffle that let a foreign group bring offshore cash into the US without paying the dividend tax. Closed by final US regulations in July 2024.
• Earnings stripping. The simplest of all: load a company with debt to a low-tax parent so the interest eats the profit. Now capped, not closed.
• Round-tripping. Send your own money offshore and bring it home dressed as foreign investment, to claim the breaks foreigners get. Constrained, jurisdiction by jurisdiction.