I think you will find this is more a Amazon / Starbucks tax, if you want to tax Google the best way would be to place VAT on advertising.
UK slaps 25 per cent 'Google Tax' on tech multinationals
Chancellor George Osborne has announced a 25 per cent tax on company profits made in UK but diverted abroad - singling out tech companies for a so-called "Google tax." In his Autumn Statement Osborne pointed the finger at large multinational companies, particularly those in the tech sector, that use "elaborate tax structures" …
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Wednesday 3rd December 2014 14:59 GMT Anonymous Blowhard
VAT for Dummies
"VAT is chargeable on advertising however it is the "customer" of Google who pays the VAT. They would then reclaim it back."
VAT is Value Added Tax; businesses can only claim VAT relief on VAT they pay on goods and services they buy, not the VAT on what they sell. The real fiddle here is to make it look like you're paying out more VAT than you charge yourself, then HMRC will be paying you!
http://en.wikipedia.org/wiki/Missing_trader_fraud
The real problem is that by making it look as if they make no profit (so no value added) they get away with hardly any corporation tax and hardly any VAT; two for one!
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Wednesday 3rd December 2014 17:05 GMT Charles 9
Re: VAT for Dummies
But they get around THOSE by (a) not allowing the taxable revenues to ever enter the country in question and (b) cook their books such that the company has NO local turnover. Either way, they basically trade in the country but have ZERO revenues to show for it, and any percentage of zero is still zero.
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Thursday 4th December 2014 17:20 GMT Anonymous Coward
Re: VAT for Dummies
"(b) cook their books such that the company has NO local turnover"
This is precisely what Starbucks do. They operate in such a way that their central 'wholesale' function sells beans and other point of sale guff to its 'retail' franchise network - at a carefully calculated premium which leaves the franchises with very little tangible profit in each of their respective local markets. This allows them to hoover the majority of the actual profit back to their central operation for distribution to shareholders and senior management.
I don't see what sort of legislation would tackle this sort of underhanded behavior, quite frankly.
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Thursday 4th December 2014 19:02 GMT Anonymous Coward
Re: VAT for Dummies
Don't be ignorant; Starbucks sells beans to it's wholly owned shops and to its franchisees at the same price as it has to to; so the transactions have the same effect as a theoretical 'arms length" third party sale. They also own their IP (basically the value of the name, such as it is) in one EU country and charge that similarly. EU Tax rules prevent the UK from taxing that revenue stream. So where's the complaint.
And all of you mug punters forget, that in the end you'll be paying any extra tax that is levied, just the said corporations will collect it for the government if they end up paying. But governments love this sort of trick, it's right out of the Gruber playbook: You are all basically too stupid to see that tax incidence means that levying a higher corporate tax = taxing the taxpayers even more but getting someone else to do it for them.
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Thursday 4th December 2014 21:14 GMT John Brown (no body)
Re: VAT for Dummies
"you'll be paying any extra tax that is levied"
And yet, other coffee shops manage to compete on price and often win on quality and they pay the taxes which Starbuck manage to not pay. So if Starbucks have to start paying taxes and they increase prices to maintain profits, everyone else will be undercutting them.
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Thursday 4th December 2014 10:14 GMT Anonymous Coward
Re: VAT for Dummies
"VAT is Value Added Tax; businesses can only claim VAT relief on VAT they pay on goods and services they buy, not the VAT on what they sell."
Yes, the goods and services are bought by the companies that buys the advertising space from Google, Google's customers.
Google sells an Ad slot for £100. Company x pays £120 for the ad slot (£100 + 20% VAT). Google pay the £20 to HMRC. Company x reclaims £20 from HMRC. HMRC net gain = £0.
Even if VAT was increased to 1000% on advertising it wouldn't increase the government's coffers.
Not sure why you are trying to give me a "dummies" lesson?
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Thursday 4th December 2014 17:34 GMT Anonymous Coward
Re: VAT for Dummies
"Google sells an Ad slot for £100. Company x pays £120 for the ad slot (£100 + 20% VAT). Google pay the £20 to HMRC. Company x reclaims £20 from HMRC. HMRC net gain = £0."
No, not quite.
You're missing the leg of the equation where Company x has sold a whole bunch of product/services thanks to its advertising spend and hoovered in a whole bunch more VAT on that. This means that they merely offset that £20 against the £1,000's they collected from end customers, and the net difference is payable to HMRC.
HMRC should ££profit££ here ... any retail company which is claiming back from VAT spend on advertising year on year than it is submitting to HMRC on sales is not in profit and is doomed(*).
(* Depressingly, been there/done that)
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Wednesday 3rd December 2014 20:36 GMT JeffyPoooh
Slap an import duty on Trademark Rights being "imported"
“Intangible assets such as IP are easier to move [than having fixed assets],” he said. “Companies such as Google and Apple are known for being particularly aggressive in tax avoidance.”
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When they export profits, import tax (duty) on whatever it is that they are claiming to be importing to balance the books. Often "Trademark Rights". Easy.
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Wednesday 3rd December 2014 13:59 GMT Anonymous Coward
Bear in mind that they've just changed the Europe wide rules for VAT, so that instead of the rate prevailing at the place where the seller pretends to conduct business, it will soon need to be the rate applied in the country of the purchaser and will go to that country's coffers.
I would guess that the Germans, French and Italians are no more happy than the British government over multinational tax avoidance, so the bleating from piss-pot tax havens that benefit (such as Luxembourg) will not be heeded, and I'd guess Ireland's defence of its low corporation taxes will be similarly ignored.
This is a good move, belated by a decade or two.
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Thursday 4th December 2014 00:51 GMT What was the question
Re: @Ledswinger
^ Faulty arithmetic there. The buyer pays ALL costs, always (assuming only that the product is not sold at a loss). Whether part of that payment goes to the government via Google or is remitted direct is irrelevant (except in terms of practicality of collection).
Google and Apple and their ilk sell for less (or book more profit somewhere in Taxhavenstan) than honest local companies. Either way, forcing an appropriate level of tax on the transaction levels the playing field.
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Thursday 4th December 2014 13:16 GMT Quotes
Re: @Ledswinger
"The buyer pays ALL Costs"
We can safely assume that if a business such as Google has developed accounting practices to avoid paying tax, this assists in reducing the price of the product/service to the end-user. This means that the end-users are currently the beneficiaries of such accounting methods, thus the tax being missed is not being exported out of the country but is being enjoyed as a subsidy on the price being paid by the end-user. It's the corollary of saying that if a new tax is levied the costs will go up.
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Monday 8th December 2014 04:02 GMT Mark 65
Re: @Ledswinger
We can safely assume that if a business such as Google has developed accounting practices to avoid paying tax, this assists in reducing the price of the product/service to the end-user.
Wrong. It reduces the cost of production and thereby maximises the profit. No savings get passed on in the modern World, margins just fatten.
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Wednesday 3rd December 2014 13:56 GMT Ashton Black
I'm confused...
To avoid corp tax, which is on profit. (revenue - costs), the UK divisions, "pay" their Irish/Other HQ for "costs" such as IP which just happens to cost roughly the same as the profit they would have made, without these HQ costs and therefore the UK division pays very little corp tax.
If this 25% is on profit, then it STILL won't be very much. So either:
1) Gidion knows this and is telling porkie pies.
2) Gidion doesn't know this and is an idiot.
or
3) I've misread/misunderstood something and am also an idiot.
Anyone help?
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Wednesday 3rd December 2014 14:30 GMT Tom_
Re: I'm confused...
It turns out that they don't give a shit if they're called out on it later. They just say it's because "warning lights are flashing over the global economy." Apparently that means they're not responsible for the state of the country's finances, unlike the other lot who were in power when the global economy went tits up who were obviously responsible because reasons.
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Wednesday 3rd December 2014 14:10 GMT Anonymous Coward
Re: I'm confused...
The whole point is that this on "diverted profits". It's pretty clear that many of the arrangements in question are intentionally designed to divert profits to avoid paying tax. You can easily calculate what a company's cost of capital is, how much capital it uses, what its group margins are, what operating costs are, and therefore estimate with some accuracy the true profit that they will be making.
US multinationals are pretty imperialistic (to the point of pig headed stupidity) so I'm sure they'll contest any changes, but with almost every European government looking to increase the tax take, they're on to a loser in the long term.
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Wednesday 3rd December 2014 15:00 GMT SolidSquid
Re: I'm confused...
That's going to be fiddly to work with though, they're going to have to be *really* careful about how the define "diverted profits" since we're really talking about companies purchasing something from other companies which happen to be subsidiaries of the same parent. Hopefully they'll find a way to deal with it, but with their track record I can't see it going well
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Wednesday 3rd December 2014 16:13 GMT Yet Another Anonymous coward
Re: I'm confused...
>"costs paid to any company in the same legal group (ie. parent company, company owned by the same > parent company, subsidiary etc...) do not count as costs for taxation purposes in the UK",
Might make it tricky to sell petrol if you can't count the cost of the oil and refining and have to pay 25% of the price at the pump along with the other 75% petrol tax
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Thursday 4th December 2014 08:09 GMT localzuk
Re: I'm confused...
@YANC & AC - Oh, yeah, my idea would need a lot of work to make it actually workable.
The problem we have is not just with internet companies, companies like Starbucks also do this by charging for branding etc... But they also charge for products imported from other countries/subsidiaries, so there'd need to be something to cover real costs.
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Wednesday 3rd December 2014 17:09 GMT Anonymous Coward
Re: I'm confused...
"I think a simple rule of "costs paid to any company in the same legal group (ie. parent company, company owned by the same parent company, subsidiary etc...) do not count as costs for taxation purposes in the UK", or something like that would help."
But some of these subsidiaries and so on are subject to the laws of other sovereign nations, which means you can have sovereign rights clash and/or complaints of double taxation.
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Thursday 4th December 2014 11:26 GMT Olius
Re: I'm confused...
The trouble is that some of these "costs" can be genuine. A franchisee genuinely does need to pay it's parent legitimate license costs and a company with a subsidury is another county may have genuine need to loan money to prop up that branch during a slightly bad year. So how does one create a fair system that isn't open to abuse?
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Wednesday 3rd December 2014 15:20 GMT Missing Semicolon
Re: I'm confused...
I don't understand why HMRC can't apply the same rules to Coporation tax as they apply to income tax - any financial arrangement that looks like it has been set up for the specific purpose of tax avoidance in the judgement of HMRC is deemed not to have taken place, so tax & NI is still due.
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Wednesday 3rd December 2014 15:37 GMT Gordon 10
Re: I'm confused...
I would guess the main reason is that Income Tax payers don't usually have a fleet of high paid lawyers on standby.....
And there are less punitive international treaties on cross taxation of corporate revenues compared to individuals income. cf the US's crazy income taxation policies where it doesn't matter where you live.
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Wednesday 3rd December 2014 17:33 GMT Anonymous Coward
Re: I'm confused...@Ledswinger
There arent many UK multinationals left because bleeding heart liberals like you have voted in morons like Gideon, who tax them to death to support all the vote buying handouts they give to layabouts and goodfornothings.
Soon, only an IDIOT would do any business in the EUC because the pig headed stupid bastards are taxing the only employers out of competivity and thus out of business. Soon, due to ignorant policies like this one, there won't be any US Multinationals doing ANY business in the UK.
If you think it easy to "calculate what a company's cost of capital is, how much capital it uses, what its group margins are, what operating costs are, and therefore estimate with some accuracy the true profit that they will be making" you must think you are a fucking mindreader as well as a socialist moron.
And by the way the British Empire INVENTED imperialism.
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Wednesday 3rd December 2014 18:27 GMT Roo
Re: I'm confused...@Ledswinger
"There arent many UK multinationals left because bleeding heart liberals like you have voted in morons like Gideon, who tax them to death to support all the vote buying handouts they give to layabouts and goodfornothings."
The ones that died while I was paying attention went tits up under the allegedly "business friendly" reign of the Conservatives. In my career I worked for two British multi-nationals, in both cases the tax bill failed to kill either of them. Like many of their contemporaries they were mismanaged into the ground or simply starved of working capital by lenders - then split up and asset stripped so that the management and bankers could make a tidy wedge while the grunts were left to try and reclaim their unpaid wages at the tax payer's expense.
In the case of Exhibit A they were unable to secure a relatively small amount of cash from lenders to develop their next gen products - so they sat on the sidelines for 5 years or so while the competition streaked ahead - unable to raise the enough money from falling sales and margins... Exhibit B's demise was triggered by a major cheese deciding to redirect a ton of company money from R&D into spaffing money on investments which tanked, and then to make it all better they borrowed a ton more money and spaffed it on more investments which also tanked...
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Wednesday 3rd December 2014 22:18 GMT Roo
Re: I'm confused...@Ledswinger
Sadly the facts behind the demise of Exhibits A & B won't change however many times my observations are downvoted. I wish it were otherwise because there was some good engineering and good people done in those places, the result was a terrible waste of potential. :)
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Thursday 4th December 2014 08:34 GMT Roj Blake
Re: I'm confused...@Ledswinger
"There arent many UK multinationals left because bleeding heart liberals like you have voted in morons like Gideon, who tax them to death to support all the vote buying handouts they give to layabouts and goodfornothings."
No, the reason for the lack of UK multinationals is that anyone can buy our businesses while other countries have rules that limit foreign ownership.
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Wednesday 3rd December 2014 15:19 GMT Anonymous Coward
Re: I'm confused...
I think Gideon is mendacious. Look at his record. I can't believe anyone would be stupid enough to create a low wage economy and then wonder, shock/horror, why tax revenues are decreasing. That's basic adding up, init?
I think the end game is:
- Government still gets the taxes it's so addicted to, for its ideological vanity projects
- While providing minimum or no services, for those taxes.
Think fist world taxes, third world public hospitals, bad infrastructure* and really scary riot police (just like Brazil).
* After all, roads don't really matter when you can afford your own helicopter.
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Wednesday 3rd December 2014 15:57 GMT Bloakey1
Re: I'm confused...
<snip>
"Think fist world taxes, third world public hospitals, bad infrastructure* and really scary riot police (just like Brazil)."
<snip>
I thought that Fist World was a publication and therefore exempt from VAT? as for Brazilians I an not sure how that would effect the activity, perhaps some form of topiary levy.
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Wednesday 3rd December 2014 16:29 GMT codejunky
Re: I'm confused...
@AC
"I think Gideon is mendacious. Look at his record. I can't believe anyone would be stupid enough to create a low wage economy and then wonder, shock/horror, why tax revenues are decreasing. That's basic adding up, init?"
The gov didnt make a low wage economy. The gov doesnt create jobs, it only has the capacity to take them away. The change in the wage situation probably had more to do with the recession that came and theoretically went but thats an amusing discussion on its own. From that point we had the simple facts to work with-
> Less money in the economy (actually the lack of money to debt was exposed, the money didnt vanish, it wasnt there in the first place)
> People in fear of their jobs
> Public spending already FUBAR and future commitments already made on top of scorched earth policies of previous government
We can ignore the first part as a larger topic but the second point is huge. The fear of losing your job causes its own issues and combined with the 3rd point a lot of excess public staff were gonna be back on the market. Normally a load of people would be out of a job and the world would end, but instead it didnt happen (yet anyway). Instead people kept their jobs allowing them to keep their income and security although it did have the consequence of not increasing their wages much if at all. The trade off and what is the good news is the employment issue that everyone feared was averted!
But as we know people dont like to be happy. So people who kept their job when they could have been cut then wanted a pay rise. The idea changing from a fear of no job to an irritation of no pay rise. Greed sets in and demands for money (back to point 1 doesnt exist) so tellies can be bought on black friday cause a fuss. How can our country be doing well with bad news? The honest answer depends how often and badly you move the goal posts.
Of course the problem is not in a vacuum as the global recession based on very dodgy world wide dealing and stupidity (not just the US and not just the banks but also govs) through to the current state of the eurozone trying to sink itself and high debt/money printing has an effect on us too.
The certainty is that public services and jobs have to be cut (this is a concept still beyond some people) due to the cost being far beyond the tax collected and that tax must go up. These awful truths are of countries living beyond their means, leaders offering bribes and pilfering the till and voters being greedy monsters who want the expensive toys and no cost. But everything must be paid for and so the children are sold. Future generations having less services and higher tax to pay for the joys we have today. And with those joys people continue to complain ignoring that they have a job and we dont look like the eurozone.
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Thursday 4th December 2014 09:55 GMT TheOtherHobbes
Re: I'm confused...
>The gov doesnt create jobs
Apart from all those public sector jobs. And the ones created by big infrastructure projects. And the ones spun off from academic research funded with grant money.
> The gov didnt make a low wage economy.
Oh yes it did.
The Tories have been playing the same old two-faced 'Bring in lots of super-cheap immigrant labour while stoking up racism to distract the noobs from what we're doing' game for literally decades now.
I'm sure Cameron is terribly, terribly sorry that he hasn't managed to cut immigration. No really, he is.
This has been going on since at least the Empire Windrush. (Possibly much longer.)
> The certainty is that public services and jobs have to be cut (this is a concept still beyond some people) due to the cost being far beyond the tax collected and that tax must go up.
That's the peculiar thing about useful public investment - it creates multipliers. If you do it right eventually you get out a lot more than you put it in.
Cutting spending in the wrong ways creates multipliers too. If you do it wrong you lose a lot more than you think, because it has a chilling effect across the economy - as Gideon has proved so brilliantly during his exemplary term as fiscal peasant-kicker in chief.
People like you, who seem to think running a country is just a bigger version of running a bank account and it's all simple, in a stands-to-reason-dunnit market trader kind of a way, shouldn't be allowed anywhere near economics, because you don't understand how fiscal policy actually works.
Keynes understood it, and Keynesians have a much better record of correct predictions than the loony monetarists and supply-siders who currently run things - but since the loonies run things for their own benefit and not anyone else's, it's debatable if this is a bug or a feature.
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Thursday 4th December 2014 11:07 GMT codejunky
Re: I'm confused...
@ TheOtherHobbes
">The gov doesnt create jobs
Apart from all those public sector jobs. And the ones created by big infrastructure projects. And the ones spun off from academic research funded with grant money."
Yes. Well said. So they cannot create jobs they can only take them away. To pay for the public sector workers (from the workers to the parasites and their expenses) the gov must take money out of the hands of those who earned it. The gov makes no money, they dont earn anything, they take it from the population to provide public services. This is something we accept as we want public health, education, etc but the money for it comes out of the pockets of people earning money. When you take money away from people they cannot spend it. So a business can be taxed out of existence, a business can be taxed out of hiring workers, a person can be taxed out of hiring childcare or cleaning services etc. All of the money the gov throws your way was taken from your pocket and a large amount skimmed to pay the admin costs before being presented back to you.
"The Tories have been playing the same old two-faced 'Bring in lots of super-cheap immigrant labour while stoking up racism to distract the noobs from what we're doing' game for literally decades now.
I'm sure Cameron is terribly, terribly sorry that he hasn't managed to cut immigration. No really, he is."
I hope you are feeling better after 13 yrs in a coma. Seriously? This gov aint doing very well at cutting immigration, and no they aint a great gov. At what point does that remove all of the years before that of exceptional immigration under the last gov? And who thought he could cut immigration when we have an open border arrangement but only if your what we class as 'European'? And the immigration debate has restarted now labour are not in power calling everyone racist after they accepted the racist open border system.
"That's the peculiar thing about useful public investment - it creates multipliers. If you do it right eventually you get out a lot more than you put it in."
That is such a true statement but not in the way you mean it. If it worked the way you think then our national debt would be falling after extreme investment by the last gov even as they borrowed during a boom and sold gold to prop up their public investment glut. If you do it right requires a crystal ball or great luck. If you keep it simple and provide the very basics then yes it is easy to improve the working situation but then it doesnt provide all the social niceties people want. The only multiplier with absolute demonstration (with multiple countries proving this) is that relying on credit increases your dependency on credit.
"Cutting spending in the wrong ways creates multipliers too. If you do it wrong you lose a lot more than you think, because it has a chilling effect across the economy - as Gideon has proved so brilliantly during his exemplary term as fiscal peasant-kicker in chief."
Cutting spending badly would cause problems as it causes a crisis in confidence so I agree with that. The gov has an array of decisions which very few provide a good outcome for the country but they rarely match the election requirements. You can call him the peasant kicker but the simple fact is the last gov borrowed to give money to those (as you call them) 'peasants' at the cost of everyone. The money does not exist, not there, an illusion, it is debt! Once you overcome that required understanding you see that those people and a hell of a lot more think they have money, but they dont. They think they are wealthy or middle class, but its on the back of debt not money. If you dont believe me then look at the amount of debt and the way it is and has been going. It gets bigger. You are blaming this gov for being honest and showing you (only part of) the true situation. Less money for the first part of your comment because it is paying off this part of your comment.
"People like you, who seem to think running a country is just a bigger version of running a bank account and it's all simple, in a stands-to-reason-dunnit market trader kind of a way, shouldn't be allowed anywhere near economics, because you don't understand how fiscal policy actually works."
It is funny how we have the same opinion of each other. I point out that cuts must be made and more tax raised and you think more should be spent and higher debt is good. I have a credit card to sell you, your gonna love it. And instead of paying for the services we want and need you think we should be paying more in interest. The hole in your argument is so huge I could fit a planet through it! I save, I work, I had no debt until my recent modest mortgage that I am overpaying. You are selling people like me because your pockets are empty! I understand that you are telling me this is a stick up because you cannot control your spending. Seek help please. And the more you cost the country the more poor people you create (you call em peasants).
"Keynes understood it, and Keynesians have a much better record of correct predictions than the loony monetarists and supply-siders who currently run things - but since the loonies run things for their own benefit and not anyone else's, it's debatable if this is a bug or a feature."
Your last line is very important. You want larger interest payments eating public money instead of funding services because you are not the loony one? And buying shiny shiny now to pass on a huge bill is not for your own benefit but for theirs? I am gonna make you soooo happy now. I offer you the opportunity to pay my bills for me. I dont care if you consider it a bug or a feature.
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Thursday 4th December 2014 12:53 GMT Otto is a bear.
Re: I'm confused...
And there was me thinking that the main reason the last government ran out of money was that there was a financial crash that substantially reduced tax income, and forced the government to spend lots of money on bailing out the banks, and benefits because of the resultant unemployment, whilst still having to pay for its commitments.
Thinking of the "Peasants" I know, I don't think any of them thought life was a bed of roses on benefits under the last government, or that they had any substantial handouts, can you? I suspect any you can think of, were earning on the side, basically defrauding the taxpayer, which, unless you are a Daily Liar reader, is actually a very small percentage.
BTW. There is a phrase that HMRC like, it's "Wholly and Exclusively", which means that VAT can't be reclaimed on every business expense, or for that matter Tax offset. A trivial advantage, is that an Advertisement wishing your CEO a happy bonus day is not VAT refundable.
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Thursday 4th December 2014 13:19 GMT codejunky
Re: I'm confused...
@ Otto is a bear.
"And there was me thinking that the main reason the last government ran out of money was that there was a financial crash that substantially reduced tax income, and forced the government to spend lots of money on bailing out the banks, and benefits because of the resultant unemployment, whilst still having to pay for its commitments."
Unfortunately there are some people who still think that regardless of the facts (shocking aint it)! We know Blair/Brown had a wonderful boom, the thing that typically comes before the crash, where they spent it all and then even more! But how did they spend more you ask? They raided earnings, they sold gold on the cheap and they took on debt. of course this also went into one illegal and one dubious war but mostly it was to feed the public the illusion that the gov were doing well. And then the house of cards collapsed and Brown was left holding the bag but had nothing to support the currency (bail banks) nor to support his over-bloated public sector (and off the books public workers). But he didnt leave it there! Brown was a master (of disaster)! he then went all scorched earth on the next gov by committing us to even more bad contracts without money to pay with.
"Thinking of the "Peasants" I know, I don't think any of them thought life was a bed of roses on benefits under the last government, or that they had any substantial handouts, can you? I suspect any you can think of, were earning on the side, basically defrauding the taxpayer, which, unless you are a Daily Liar reader, is actually a very small percentage."
Nice argument but those aint the people I was talking about (and peasants wasnt my choice of word). How many people are propped up currently by the low interest rate just so they can keep their house? How many people were employed into a bloated public sector and how many non-jobs or excesses had to be cut when the truth hit home? How many people are not getting a wage rise because the money dont exist and how many people rely on the wage rise to fund their existence? In some cases those people overspent on credit (I expect quite a few) but also those who didnt were still living on credit, the government! And the worst part is they wouldnt have known it. The unsustainable spending spree was based on an assumption 'No more boom or bust' do you remember? That was the hope, fantasy and dream that underpinned all of that spending. At great cost to the people now. Dont believe me? Then you can prove there is no deficit (and no you cant).
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Biting the hand that feeds IT
