Re: Thre is a slight problem with this
It was specifically noted that the deal freed Google from the future problem of the diverted profits tax. On hte basis that they're not diverting profits.
1332 posts • joined 12 Feb 2008
It was specifically noted that the deal freed Google from the future problem of the diverted profits tax. On hte basis that they're not diverting profits.
Which is that the Google Tax hasn't worked in the UK. Not even on Google.....that recent tax deal was absolutely nothing to do with the diverted profits tax and actually, the settlement itself frees Google from the diverted profits tax.
The reason to send HEU to the US is because they have a system, built and in place, to blend it down to LEU suitable for use in reactors. This is one of the (few?) things that Al Gore got right. Get that HEU out of Russia and into US reactors and spend however much money necessary to do so.
You do not use HEU is energy production reactors although you might, just, use it in one or another design of isotope production reactors.
And yet the US has been driving a worldwide campaign to get people to stop using HEU for medical isotope production because of those proliferation issues. To the point that they will come in and build an LEU using production reactor and even finance it.
Thus, HEU goes off to the US, the US then supplies back LEU suitable for isotope production.
It all entirely makes sense. But of course someone at The Conversation who wanted to complain about nuclear waste, an entirely different subject, wouldn't bother to tell you all that.
How would anyone know without trying it?
My career, such as it was, in tech journalism was entirely untroubled by ejaculate covered images of myself. Clearly no popularity at all among gay men or girls who gush.
However, there is a bit that I don't understand here. We don't have to get entirely all Simon Baron Cohen here but the tech industry is rather heavy on the "nerd" sector of the population. Nerd having two slightly different meanings at times, one "interested in tech and engineering" and one "not all that good at social interaction". The bit I'm not getting being why is there all this vocality about the sector "tech and engineering" being full of people "not very good at social interaction"?
It's rather one of those things that goes with the territory, isn't it? Like complaining that man sheds don't come with lace doilies, or that the graduate students in French Romance poetry don't seem to be very good at maths.
Admittedly, I do get easily confused. I recall a very pretty young Randian Objectivist insisting that one of the joys of the philosophy was that it allowed her, nay encouraged her, to have decent sex when- and where- ever. OK, fine by me, but why did she get very pissed off when I made a pass at her?
It's not quite as exciting as all that. UK based salesmen closing deals with UK customers always would be a "permanent establishment" in the UK and the profits from such would always be subject to UK corporation tax.
So, what they're saying is that "our large customer salesmen are based in the UK". Everything else flows from that.
Including, funnily enough, that Facebook UK will now be paying royalties to Facebook Ireland. Because tax is indeed levied where the economic activity takes place and some good part of Facebook's economic activity is all that development work done in California. Meaning that, under those usual tax laws, Facebook UK *must* pay a royalty from that UK income. And that royalty moves through Ireland, to Bermuda and then, maybe yes, maybe no, into the US.
What the net effect of this will be is going to be interesting. I can see the tax bill rising, yes, but I wouldn't expect it to be by all that much.
Buy an MSP?
Hmm, Members of the Scottish Parliament are pretty cheap but I'm not sure what I would do with one....porridge tester perhaps?
I'm thinking of it more as a way to advertise an agency that does magento. But everyone's warnings much appreciated: and once they've been made I can see the relevance of them too.
The current project is much more fun: mapping tornado damage for FEMA in a Ruby/Rails system.
Care to drop me a line about this? I think the email attached to my pieces here still works. If not, timworstallAT"taxdodger"gmail.com does.
I'm looking around for an entry level service that we might offer (me and my team of Czechs) and this is the second Magento problem I've seen in a couple of months.
"We patch your Magento system for $20" might be something we could usefully do. Or some other similar sort of price. Would love to get some guidance from those who know whether that's something that might fly.
Not quite, no:
"What you quote them as saying here is that, given that the current tax system is based on taxing corporations on the profits they make in this country,"
I effectively call them idiots because that is *not* how the tax system currently works yet they are claiming it does.
"transfer pricing to transfer profits across borders is illegal."
"but they've been curiously uncurious when it comes to investigating Google's trading arrangements, or Starbucks' bean purchasing."
Nope. Starbucks first. They paid a margin of 20% on the cost of beans to their own subsidiary in Switzerland. Note that beans are cheap, maybe 5 p on a cappuccino.
So, what do the transfer pricing rules say? That a company must make sure that trade between two subsidiaries happens at market prices. That is, no special prices, no deal, to move money around in order to shift profits.
So, do you know any coffee bean brokers who are willing to buy, grade, sort, store, coffee beans with out being paid a margin to do so? Quite: so Starbucks *must* under transfer pricing rules pay some sort of margin to its Swiss subsidiary. Maybe 20% is too much. But for them *not* to pay a margin would be a breach of the transfer pricing rules.
Google is differently to do with the transfer pricing rules. The sales are made into the UK by Google Eire. That's Ireland's money, nothing to do with the UK. EU law that is, any EU company may sell anywhere in the EU and pay tax in whichever jurisdiction it calls home.
If Google had no office at all in the UK there would be no argument over this at all.
Google does have an office in the UK. The argument is not over the ad revenue again. It's over how much Google Eire pays Google UK for their engineering services and support. HMRC is saying that proper arms length transfer pricing would include a bit more margin for Google UK. Google has grudgingly agreed.
It's absolutely not about the ad revenue at all.
Now, maybe the law should be different and maybe it shouldn't be but that is the argument within the law as it is today.
Finally, the idea that the big boys get special treatment. Err, no. The loophole that is being exploited here is one that is available to every small company. I've used it myself, multiple times. So, I sell some Ruby/Rails programming services into the US from the Czech Republic, as I just have done. US revenue from US customer. Should I now file a US tax return, pay US taxes? Nope, I'm a small company, I don't have a base in the US. So, to keep the world simple, to allow small companies to actually export, Aw, Heck, just pay the tax at home, to the CR.
*That* is what Google is doing, exploiting the permanent establishment rules put into the law to *aid small companies*. And every small company that does export is doing exactly the same thing.
I do the insult indirect to Murphy and Sikka. Up above Andrew has gone for the insult direct: "innumerati".
And you want to shout at me about it?
I haven't actually said the employees should be taxed the equivalent. Rather, I've said that the economic incidence of corporation tax is upon 1) The shareholders in the company being taxed and 2) All the workers in the economy applying the corporation tax.
It is a basic and known economic finding that the corporation, as a corporation, does not bear the economic cost of the tax: only people can do that. So, instead of taxing the corporation why not just tax people instead? Comes to the same thing in the end but it's rather easier to just tax people: as this story is showing.
It really depends upon the specific item under discussion. Ores can be identified pretty well by location. Not isotopes, but trace elements can be tracked and each ore body is different.
But the real problem is then processing. If you've something where artisanal processing is possible (say, gold or tin) then you have no hope at all of being able to track material. OK, I can't do it but it can be done, to make metallic tin out of cassiterite with a bunch of rock, some charcoal and some cheap labour. Might not be all that efficient but it would get you something pure enough that a scrap merchant would buy it. Same is true of gold. And once you've got something that can be sold to a scrappie then of course there's just no manner at all of tracking it.
Tantalum is rather different. You've only got 15 or so plants around the world that can possibly process the ore. Requires HF, which just isn't something that is going to be handled in an artisanal manner.
Control or not control is something that depends upon the details of the specific technology of that mineral.
Don't actually know enough about cobalt to know which way that one goes.
No, he wasn't......
The actual suggestion that AI will make soon enough is that Co should be added to the W, Sn, Ta and Au restrictions. That Blood in the Mobile stuff.
The problem with this, as in El Reg passim, is that it's a grossly expensive and ineffective way of doing it. It cost US corporations (and US listed corporations *only*) $4 billion to bring in the last set of regulations and processes. To no very great effect that anyone can see.
Face masks and a bit of education on shoring up mine workings would appear to be both cheaper and more effective.
Well, the Starbucks and Fiat cases were about Luxembourg and meant €20 and €30 million in tax respectively.
The €750 million one in in Belgium and is for 35 companies over 10 years: about €2 million each.
This is all nibbling around the edge of the tax system, not undermining the basic principles. And Bloomberg here is appallingly wrong.
Their basic method of calculation is as follows: we've heard that Apple's going to lose that EU case. OK, so, what would be Ireland tax on all Apple's overseas profit: $8 billion.
But that's to miss what the EU case is about. It simply isn't about the Double Irish, nor the way that IP rights are held in Bermuda. And it's that which makes Apple's tax bill so low. Profits pile up in Ireland, the Bermuda company then says you must pay for the IP and off the money goes.
This isn't being challenged, it's not being investigated and the EU has no power over it anyway.
What is being investigated is some minor issues over how Apple's profits made from actually working in Ireland are calculated. Best informed guess is that, if they lose, bill of maybe €200 million to cover a decade.
Bloomberg seriously misfired on this one.
There will be no penalties. Because it's a "state aid" case. Meaning that whoever has done something wrong it's the government, not the company.
Can't see it working for me really.
Given past decades of experience the idea that there's two people, simultaneously, on the planet who desire to have sex with me is difficult to believe. That there's two or more simultaneously who desire to do so simultaneously.....
Lewis, I don't know I'm afraid. Seen some stuff in the Telegraph from him. I'm at Forbes, as I ever was, plus there's my blog at myname.com
Snigger, yes, that is very amusing. But I think Gordon 10 has it right there, it's the end of the Weekend Edition.
There's also an amusing difference between the active and passive to be noted, between "were moved on" and "decided to move on".
Have to admit to being a bit mystified here.
One of two things has happened. Apple has screwed up the paperwork. Or Italy is over turning the standard international taxation order. Need more detail of what actually happened before working out which.
Did some pencil sketch numbers about running a Kickstarter to produce an alt-mag. Just couldn't see 10k people chipping in $100 each to give a two year run at doing it properly. Just not on. And as for trying to do it commercially.....have you seen ad rates these days?
That is indeed exactly how it works.
Thank you for that.
And the Worstall response here would be to use the word "elastic" in its economic sense. Nothing is infinitely elastic nor inelastic. Everything sits on the spectrum of elasticity.
And cloud supply is obviously more elastic than dedicated supply of computer cycles.
At which point, well, yes?
Worstall no longer writes a weekend column for El Reg. Thus there's nothing missing.
And just to make my, Worstall's, opinion of this clear. El Ed has an absolute right to deploy his resources, his freelance budget, as he sees fit. I thoroughly enjoyed writing for y'all and also have no complaint whatsoever about El Ed deciding it's something that didn't quite work out as perhaps hoped.
Hmm, dunno. A quick search for "alumina in glass" brings up, first page, a paper from 1947. So it's not exactly a new idea. It's the method to get a high alumina glass, not alumina glass, which is new.
My problem here is that David Walker is the name of the husband of Polly Toynbee.
Got me very confused, that did,
I'm glad I was able to engage your interest.
But then they already are on AIM anyway.
Globo anyone? Sino-Forest? (Not AIM but still). And that telecoms one from last year? Quindell.....not a scam but "interesting" all the same.
Sad creature that I am I bothered to look up their numbers.
An 18% rise in the risk of colorectal cancer.
From perhaps 50 cases per year per 100,000 people to 60 cases per year per 100,000 people.
Not exactly the terror of the worlds that some newspapers seem to think it is.
Economics at university these days. Lots and lots of mathematics to feed the macro models. Got to be done but that's the very boring part of the subject. There will be lots of mandatory courses in all that stuff. For enjoyment, tell her she might want to sample, as her electives, bits of political economy, micro theory, public choice, anyone who is teaching Mancur Olson and so on. Even a light introduction to Marx can be fun (but don't go the whole hog and actually believe it).
And there will be lots of statistics. But make sure that you understand the underlying concepts, not just the manipulations. Because much fun (for an odd value of "fun") can be had by reading the various pressure group reports and seeing how they've ignored those basic concepts in constructing their numbers for public consumption.
Called the "wealth effect". We think we're wealthier, we spend more. We think we're poorer, we spend less.
Is why there was going to be a recession in the US whatever happened to hte banks: $8 trillion in housing wealth was lost.
Umm, sorry about this but couldn't resist.
If you've two of them does that mean you need both hands to find them?
That would actually make a good column of this type. Jean Tirole and dual facing markets and all that. Often that would be the genesis of one of these. A comment, some pondering (as I did while trotting the dog around the Portuguese countryside just now) and then a few notes....and then I find I'm late for the pub but the article has been filed a week early. The subs loved that.
I shall be on time for the pub today though.
I used to write for them occasionally. Matt Seaton used to like prodding the commenters occasionally with a neoliberal style pointy stick. He moved on from CiF and he same changing of the guard of the freelances happened. His successor was less keen on that prodding with the pointy stick....
"The harm is that if vacuous bullshit is allowed to be published,"
It could just be that censorship is an over reaction to the quality of either my logic or journalism.....
So you've more faith in macroeconomics than I do then :-)
Microeconomics is the bit I think we've got good parts of correct.....
Barter isn't taxable, no. Unless you start using money to keep score of it, when it is. And barter also doesn't occur in GDP, only measures monetised activity. One of the known problems with it.
The uncertain future of the Lancashire dusk is......
Flogging the time and skills of my excellent network (or perhaps network of excellent) Central European programmers. Ruby on Rails and similar a specialty. We've got our first couple of contracts and I'm not difficult to find (timworstallATgmail.com gets to me) if that's something you're looking for.
The way that freelancing works is rather similar to, say, courtiers (or Cabinets). One particular editor will have certain people that they prefer to use. Another will have others. And when that editor changes then who among the various entourages gets used also changes.
Nothing wrong with such a system: it's how an editor advances their vision of what a site should be.
And everyone in the game knows exactly what the game is.
Absolutely no complaints from me, I've thoroughly enjoyed my time doing these columns. And it's not everyone who is able to say they've had an entire years' worth of well paid work that they've thoroughly enjoyed doing.
And it is of course you ladies and gentlemen that have made it all so enjoyable. It's thoroughly refreshing to write for an intelligent and inquisitive crowd. This is one of the very few places I've ever written where "commentard" isn't in fact the correct word to use. Yet we use it anyway, eh?
There is also this:
Perhaps a bit more specialised. And Computer Weekly has taken their first piece.
Surely it should be faasands of 'em, not thousands. Don't we want to get that other great war movie into it?
"pushing its agenda to the detriment of all else isn't lost on Page"
You're absolutely right, it depends upon what you consider to be "wealth".
In theory, every church is owned by the Church. Which is a pretty big real estate portfolio. And I doubt there's a mortgage on much o it.
But a decent net value would try to take things like maintenance costs into account. And I very much doubt that any of them run at a profit on that basis. So maybe the net value of that real estate is negative?
Mean wages have risen rather nicely in the US over that time. Median wages not so much. But Krugman's original point was about mean wages.
To show that economics is a generally applicable set of rules, whether that qualifies it as a science or not, let's walk through the basics of climate economics.
Humans are subject to hyperbolic discounting. That is, we value the future less than we rationally should do. Our estimations of the costs (and benefits) of future events seem to go a bit wonky 20-30 years out and further. I link this with our being a species that by long experience (the time is longer now) has generally had about that much adult lifespan to enjoy. We might also link it with Sir Pterry's "grandfather".
Stern and his Review said that they way to counteract this was to use not market interest rates to estimate the future, but much lower rates not subject to that hyperbolic discounting. He's right in theory.
Sir Partha Dasgupta said the theory is right. But the actual rate is far too low. Because, if we accept Stern's rate, then rationally we should be investing up to 98% of current income in investing for the future. On very much the grounds you are thinking about science on. Because we should value the future being richer than we are more than we do, and if we do that at the rate Stern says then that's the amount of our current income which we should be spending on that knowledge that will make the future richer well after we're all in our (paupers') graves.
So, the framework within which economics thinks about this, and climate change is a public good (although when it's not good we call it a negative externality) just as future MOAR SCIENCE is a public good, is what is the discount rate we should be applying to the costs of foregoing current consumption to gain that greater wealth for the future.
98% of current consumption for MOAR SCIENCE won't get past most peoples' bullshit radars even if people seem to accept it for climate science.
Ultimately though it comes down to what you think economics is, normative or positive. Should we be describing what ought to be done or should we be describing what is done? And if we take the positive route (which most economists generally try to do) then we come back to, well, people seem to value future MOAR SCIENCE at rather the interest rates that they view most other things in the future. At market interest rates.
Perhaps, according to some standards, they shouldn't. Maybe that hyperbolic discounting is "wrong" in some manner. But that is how humans act and it is us humans we're trying to maximise the utility of.
Alternatives have been tried: the Soviets spent vastly more as a proportion of current production on science than we ever have done. Pretty spiffy stuff came out of it too. But it was few peoples' definition of the desirable society.
Leading to a weak conclusion: spending on future public goods should be what people will put up with having taken out of their current consumption.
Dismal science is a very good name for it. Thomas Carlyle wanted to argue that slavery was just great because we pink people were so much better than those melanin enhanced ones. Economists then pointed out that paid labour was actually more efficient than slave labour.
Thus Carlyle called it the dismal science because its facts meant he didn't get to play out his Mandingo fantasies.
Strange what you can prove with something that just isn't a science, isn't it?
Alex Tabarrok has something called the Tabarrok Curve. Akin to the Laffer Curve.
We want some IP protections in order to make research and innovation profitable. But it mustn't be too strong, over the peak, and deter too much derivative innovation. We're past that peak, well past it, he says.
I tend to think that came before humans so isn't really an invention. Adam Smith talked of the innate tendency to truck and barter. And we do have good evidence of pre-homo sapiens trade in things like flints and knapping stones.
Actually, bacon has its merits. If you think of it as an exemplar of the ability (or even idea) to cure and thus store food for consumption later.
Meaning that our civilisation is in fact built on beer and bacon. Sounds good to me.