"earnings-stripping"). The Netherlands has been a leader in this area, using specifically worded legislation to enable IP-light companies further amplify "earnings-stripping". This is used by mining and resource extraction companies, who have little or no IP, but who use high levels of leverage and asset financing. Dutch tax law enables IP-light companies to "overcharge" their subsidiaries for asset financing (i.e. reroute all untaxed profits back to the Netherlands), which is treated as tax-free in the Netherlands. The technique of getting full tax-relief for an artificially high-interest rate in a foreign subsidiary, while getting additional tax relief on this income back home in the Netherlands, became known by the term, "double dipping". As with the Dutch sandwich, ex. Dutch Minister Joop Wijn is credited as its creator. Irish Section 110 SPV The Irish Section 110 SPV uses complex securitisation loan structuring (including "orphaning" which adds confidentiality), to enable the profit shifting. This tool is so powerful, it inadvertently enabled US distressed debt funds avoid billions in Irish taxes on circa €80 billion of Irish investments they made in 2012-2016 (see Section 110 abuse). This was despite the fact that the seller of the circa €80 billion was mostly the Irish State's own National Asset Management Agency. The global securitisation market is circa $10 trillion in size, and involves an array of complex financial loan instruments, structured on assets all over the world, using established securitization vehicles that are accepted globally (and whitelisted by the OECD). This is also helpful for concealing corporate BEPS activities, as demonstrated by sanctioned Russian banks using Irish Section 110 SPVs. This area is therefore an important new BEPS tool for EU corporate tax havens, Ireland and Luxembourg, who are also the EU's leading securitisation hubs. Particularly so, given the new anti-IP-based BEPS tool taxes of the U.S. Tax Cuts and Jobs Act of 2017 (TCJA), (i.e. the new GILTI tax regime and BEAT tax regime), and proposed EU Digital Services Tax (DST) regimes. The U.S. TCJA anticipates a return to debt-based BEPS tools, as it limits interest deductibility to 30% of EBITDA (moving to 30% of EBIT post 2021). While securitisation SPVs are important new BEPS tools, and acceptable under global tax-treaties, they suffer from "substance" tests (i.e. challenges by tax authorities that the loans are artificial). Irish Section 110 SPV's use of "Profit Participation Notes" (i.e. artificial internal intergroup loans), is an impediment to corporates