back to article European Union divided over tax on digital tech giants as some member states refuse free money

European efforts to implement a digital sales tax have stalled after Ireland, Sweden and Denmark yesterday stood firm in their refusal to approve measures aimed at scraping more cash in from tech giants. Governments are engaged in an ongoing battle over how to tax tech giants that often have little or no physical presence in a …

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Facepalm

Enough said...

... If at least one US legislator has already cottoned on, expect others to too. And yes, this is *exactly* what I referred to 2 months ago (go and cruise through my previous responses, it's in response to member 'Arthur the Cat'). What goes for the goose goes for the gander. Ireland knows which side its bread is buttered on, and Sweden (especially them) and Denmark and others are also getting a glimmer of what this may mean to their own digital giants. Spotify and Soundcloud are both Swedish and are exceptionally popular; so you can see where this could go if/when the US retaliates against the EU's digital services tax.

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Re: Enough said...

Are either Spotify or Soundcloud all that profitable though? Google and Facebook pay very little corporation tax, but make large profits. I guess we can also include Apple here - but I don't know if they count - but I suppose all those iTunes revenues might. Amazon are also now starting to churn out massive profits from their cloudy bits - but still not paying that much tax, which they could justify when they re-invested all their profit.

The real problem here though is the EU Single Market. It's much more efficient for a company to be able to sell across the whole EU from one single HQ. Especially as it allows small and medium sized businesses to do this. And of course then pay all its tax in its home country. However if all the massive profit makers can base in say Ireland, with corporation tax at half the level of many other EU countries, then not only does Ireland get lots of lovely extra tax, but the larger countries aren't getting any - which they would if they weren't in the EU or the Single Market didn't work this way (but would then be less efficient). Though I'm sure there'd be tax shennanigans to try and offset costs from other bits of the business against those profits, to pay more tax in jurisdictions with lower rates.

It's a hard problem to solve.

But it's actaully quite an urgent problem. I don't think it will "save the high street", as online shopping is still going to be cheaper and more convenient anyway. But I've seen an estimate that 80% of the growth in advertising sales for the last couple of years went to Google and Facebook. An awful lot of the media is funded by advertising, and we need a free and independent media if we want to have a working democracy. So not only are Facebook and Google really good at spreading fake news, but they also starve a lot of the people who try to fact-check news of funds.

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Re: Enough said...

@Spartacus, the digital services tax is not on profit. It's on revenue. See this?

The EU's proposed tax is a 3 per cent levy on firms with a global annual turnover of €750m and annual EU revenue of at least €50m. This would hit around 200 companies and boost member states' coffers by about €5bn.

The bold is mine. So yes, Soundcloud and Spotify would most certainly fall into this. If the US goes for a tit-for-tat response (which, given the current administration, they are likely to do), both Swedish digital giants would see a fat slice of their profits go to Washington, D.C.

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Re: Enough said...

anothercynic,

Thanks. The UK tax, which is actually in the process of being enacted, is only on companies that make profits over a certain amount As well as having large turnovers. It's also only due to be 2%.

I hadn't realise the EU one wasn't as well designed. Not that it's going to happen anyway, because Ireland will almost certainly veto it - as well as others probably.

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Holmes

How about fixing the existing tax code to cover this??

I don't want to add a tax to large companies that are not or barely profitable. So how about fixing the existing tax laws to get rid of shady tax strategies such as the "Double Dutch Debit", the "Irish Shower", "Lax in Lux(embourg)" and "Nobody ever goes to Jersey, but somehow our multi-billion dollar company is headquartered there"??

If nothing else, pass an EU wide corporate income tax for specific types of companies that are problematic, so that wherever you operate in the EU these companies pay the same tax. Then we can have companies locate their HQs based on the quality of the local workforce and the local infrastructure and culture.

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Re: How about fixing the existing tax code to cover this??

I don't want to add a tax to large companies that are not or barely profitable

Depends on how (taxable) profit is determined......

If you have large "management/licensing" charges levied in a separate tax jursidiction then the taxable profit can potentially be adjusted/minimised accordingly

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Re: How about fixing the existing tax code to cover this??

I don't want to add a tax to large companies that are not or barely profitable

You are missing the point.

Several global companies of note are deliberately running at minimum or no profit for 10 odd years now to destroy any competition.

One option is to go communist and make Suslov's scribes happy (tax on turnover was a stable in the economics textbooks on the other side of the wall).

The other option is to apply what is currently part of the company code as applicable to financial industry in most European countries.

1. Minimum capital.

2. Minimum dividend and mandatory changes of board and regulatory intervention if the dividend is not paid.

Just define 1 relative to turnover. The precedent is there - VAT and friends. You are simply not allowed to operate without full VAT registration if your turnover is past a certain size.

Turn over of 100Bn with a capital of one pound? Excuse me, where did the rabbit go and is he drinking tea with the Hatter and the door-mouse again.

The second option is significantly better for overall corporate governance compared to taking a leaf out of the Communist economy books (we know where that one ended).

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Anonymous Coward

Re: How about fixing the existing tax code to cover this??

Unfortunately nothing will change whilst there are still clapped-out politicians planning for cushy retirement home 'jobs'.

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Re: How about fixing the existing tax code to cover this??

"If you have large "management/licensing" charges levied in a separate tax jursidiction then the taxable profit can potentially be adjusted/minimised accordingly"

I believe that in some jurisdictions there are already rules in place that do not allow a company to charge itself (for example a local or international parent/subsidiary) significantly more or less than market value for these services.

For example if global coffee prices are $x/kg, Starbucks Switzerland aren't allowed to charge Starbucks UK $2x/kg. If Google US transferred it's IP to Google Bermuda for free or for a nominal sum, Google Bermuda cannot charge Google UK anything for use of that IP. Don't allow companies to invent out of thin air the values of intangibles such as image rights, goodwill, etc, but have them pegged to real balance sheet items. A lot of rules and mechanisms already exist for this in the tax codes, they just need to be enforced properly.

Of course that would not solve the problems of for example, Amazon operating at near-zero margin to eliminate competition, but that can be addressed under antitrust law.

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Pirate

Re: How about fixing the existing tax code to cover this??

So how about fixing the existing tax laws to get rid of shady tax strategies such as the "Double Dutch Debit", the "Irish Shower", "Lax in Lux(embourg)" and "Nobody ever goes to Jersey, but somehow our multi-billion dollar company is headquartered there"??

Because it operates under the rules of the Single Market. No single market, no problem. Problem is the rules that make this a thing won't change before hell freezes over.

If nothing else, pass an EU wide corporate income tax for specific types of companies that are problematic, so that wherever you operate in the EU these companies pay the same tax.

Won't solve the problem and would trigger many referendums that would certainly fail in a whole bunch of countries. You'd turn even Luxembourg into a country intent on leaving the EU. They don't want a fair tax system, and that's the problem and why this will never be a thing, a lot of countries are quite happy with how things are thank you very much.

The key to this is being clear about what we're talking about and then doing it right and doing it fairly - I do see why Hammond has done this unilaterally (I always suspected this was going to be the case). If they're paying tax at a rate that smells sensible they shouldn't be fair game - if they're providing minimal value to a country and potentially even actively harming it, paying no tax and located somewhere they pay almost none like, I don't know, Facebook then the system is unfair and measures to correct should be applied. The UK tax system is exceptionally simple, and we need to stop being taken for a ride by companies making massive revenues and synthetically buried (by moving) profits for the avoidance (and evasion) of tax here. If they don't like it they have the choice to not serve customers in the UK.

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Re: How about fixing the existing tax code to cover this??

....pegged to real balance sheet items

Intangible Assets (predominantly Goodwill - as in Brand presence etc.) are already real items (notwithstanding their intangibility!) capitalised on the Balance Sheet and subject to agreed valuation (and review) criteria under various Accounting Standards (e.g. IFRS) rather than invention out of thin air.

Goodwill can be subject to impairment also which may require a write-down in its value in-year.

It CAN therefore be used as a metric for the case you mention as it is measurably quantified.

Note that I am NOT saying that this kind of profit transfer/tax shopping leading to minimal profits is defensible, merely it is within the law and other regulations (e.g. IFRS)

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Re: How about fixing the existing tax code to cover this??

I'm surprised the Chancellor brought in a measure to tax companies in 2020 that will be surely overtaken by Brexit. When we're not in the Single Market anymore, surely companies won't be able to book UK profits in Ireland/Luxemburg/Netherlands, as now? So I guess as the system is only "a consultation over details", it can always be changed to meet whatever relationship we end up having with the Single Market.

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Re: How about fixing the existing tax code to cover this??

Voland's right hand,

I don't think we should do anything that was in a Communist economics textbook. In general turnover taxes are a really bad idea. Though the UK proposal is set low and only on profitable companies - so it's crecognising that and doing it for simplicity. They can always choose to register a presence here and pay proper corporation tax - if they think they're being overcharged.

We can't set minimal capital and dividend for companies not listed on our stock market. Although I can't think of a financial regime does that anyway...

VAT is not a turnover tax. It's a consumption tax.

VAT has an almost identical effect to a sales tax, it's just much more cmplicated. The advantage of that complication is that the government gets better economic data and fraud is easier to detect. The downside is the extra costs and paperwork imposed on businesses.

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Anonymous Coward

Re: How about fixing the existing tax code to cover this??

"Because it operates under the rules of the Single Market. No single market, no problem."

That's somewhat oversimplifying. Taxes also mysteriously disappear in the Isle of Man or the Channel Islands, and sometimes between the US and the EU. Tax heavens were not invented by the EU.

The single market helped avoidance in some cases, because specific countries were eager to find ways to abuse it (and some of those ways were not legal). There are loopholes to close, but let's not throw the baby out with the bath water, shall we?

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Re: How about fixing the existing tax code to cover this??

When we're not in the Single Market anymore, surely companies won't be able to book UK profits in Ireland/Luxemburg/Netherlands, as now?

This is a simple one - because Hammond doesn't think we're going to leave the single market and that it's up to him. I very strongly hope and would suggest to the government as a voter and 40% tax payer (and FWIW as a party member under 40 - we're a rare breed) that this isn't a thing.

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Re: How about fixing the existing tax code to cover this??

"In general turnover taxes are a really bad idea"

That's a little short on proof: why is it a bad idea ? It's easier to check, and makes high-volume/low-margin commerce - such as Amazon and HFT - less profitable. That's actually what economics Nobel price (1) winner James Tobin proposed. So you had better come with very good arguments why this is a bad thing.

VAT has an almost identical effect to a sales tax

yes, and that is, by definition, a tax on turnover: the consumer pays the tax on the quantity he buys. It's a buyers-side turnover tax. So that's a good idea then ?

(1) yes, I know

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Re: How about fixing the existing tax code to cover this??

Zolko,

VAT and sales taxes are taxes on consumption - not on business turnover! This is really important to understand. It's basic tax incidence - because the tax falls on the consumer, not the business.

The reason that it's not a turnover tax is that businesses don't pay VAT. Therefore if you're a company that sells to both consumers and businesses - only the consumers pay VAT - i.e. they end up paying more for the same goods than the business customers. It's not a turnover tax, because you ignore it in your accounts - I mean there's lots of shuffling around, but sales and costs are reported excluding VAT - all that stuff is diverted into your VAT account and then the net of that paid to the government every quarter - or month if you're big enough. So there's all this money changing hands, and the finance department have to worry about cashflow (as you pay invoices with VAT) but all the business people only talk net figures, and ignore it.

I don't believe Tobin was calling for a tax on retail! The Tobin tax was designed to make short term share/bond ownership less profitable - and therefore relatively rewared long-term ownership. It was not designed to punish retailers for choosing to make smaller profits than their rivals.

It's also not a turnover tax either. It's a tax on buying shares/bonds. I've not read his papers, but I'd assume it's there as a "sin tax" i.e. to discourage certain behaviour. As well as to raise revenue supposedly painlessly. The turnover of a finance company is the services they're selling to their customers - whereas a Tobin tax would be a tax on transactions - but nobody but market makers make all their money out of transactions, so it's an increase on costs. A turnover tax on financial companies would be a tax on their turnover - i.e. a percentage charge on their total sales.

As happens HFT is a great idea, in theory. It makes markets more liquid, more transparent and lowers transaction costs and arbitrage. The reason it's probably not a good idea is the risk when that market liquidity is withdrawn - which is why traditional market makers are probably a much better idea. But wasn't Tobin's work from before HFT was a thing?

Anyway when the Swedish tried a Tobin tax something like 70% of their stock market transactions disappeared overnight. Perhaps they set it too high? However London has had a stamp duty forever, and is the top or second financial market in the world, so it's not impossible. But when the EU looked at a Tobin tax a few years ago, the Commission's calculation was that it would raise something like €20-€30bn - which isn't chicken feed but isn't that much over such a large market. However it would reduce growth in those countries by 0.1-0.2% - every year. Which meant I think that it wouldn't even have a positive effect on governent revenues in the first year, basically other taxes would fall more due to the drop in growth. As well as basically costing a growing amount of money to the economy forever. Also if they made people more reluctant to buy government bonds, it would have made the Eurozone debt crisis even worse.

Anyway I'd argue the most advocates of a Tobin tax are engaging in wishful thinking. The idea that you can raise taxes without pain is just silly. You can't make someone else pay them, as that someone else will then have less money to pay you, and so everyone suffers.

But you've also not understood it. It's a financial transaction tax and not a turnover tax.

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Boffin

Life's not fair

The only "fair" solution would be a profits tax, levied in the country where the income was generated. But if you have a UK resident clicking through a Chinese advert, paid for into a Bahamas offshore bank account, placed on an American company's website hosted in Finland, how do you decide where the income came from?

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Re: Life's not fair

I think you answered your own question when you wrote you have a UK resident clicking through.

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Re: Life's not fair

VPN anyone?

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Happy

Re: Life's not fair

... then countries which monitor/restrict internet access more, will end up getting less tax revenue due to more vpn usage!

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Stop

the laws of unintended consequences

per-packet taxes mean fewer packets

per-transaction taxes mean fewer transactions

Using a country's IP address blocks to levy taxes means increased VPN usage (as mentioned above) to avoid taxation.

Do you _REALLY_ want "a tollbooth" on 'teh intarwebs' ? I don't.

And what effect would DRIVING COMPANIES AWAY from your country [not being a 'tax haven' any more] have on INCOME TAXES from employees that WORK there? [this could be moot if an entity is simply a shell company working as a pure tax shelter, which would have few or no local employees].

But yeah, if you drive them AWAY, your tax revenue will be ZERO. Understandably, nobody's gonna just BEND OVER and TAKE IT when gummints impose taxes and regulations.

unintended consequences are OFTEN the direct result. And politicians NEVER "get it".

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LDS
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"VPN anyone?"

Useless, unless you allow anonymous purchases in bitcoins - otherwise an invoice must be issued to someone, and the payment as well must come from someone.

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Re: the laws of unintended consequences

"Using a country's IP address blocks to levy taxes means increased VPN usage"

Internet purchases are typically made by credit card which are registered to a country. Physical goods delivered need a shipping address. Using IP address to determine tax location is not only unnecessary, it's nonsensical.

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Re: the laws of unintended consequences

Using a country's IP address blocks to levy taxes means increased VPN usage (as mentioned above) to avoid taxation.

Are you really saying that because of edge cases we shouldn't do anything about this? People aren't going to use VPNs to use facebook purely for the intent of pretending they're in Ireland just to save Facebook £0.0000000000001 a year, that's *insane* to even suggest.

If it's a sale of an actual thing leaving the EU fixes this problem because customs, if it's a company intent on making no margin because services they either play ball or get lost - this by the way is perfectly doable by Facebook saying what percentage of their user base are in the UK and figuring out what is what from there - there's actually no need to not trust their numbers on this; even as it relates to tax, until proven otherwise. Also by the way being banned from booking UK ad sales to the RoI when we leave the EU.

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Anonymous Coward

Re: Life's not fair

"I think you answered your own question when you wrote you have a UK resident clicking through."

Not at all obvious. Wasn't it generated rather where the actual service was realized? And where was that? Was it on the screen/speakers of one user, that might be a different one? Or was it in a datacenter? Or was it where the contract was generated (as those T&Cs very often stipulate, you might recall)?

Go talk to a lawyer, you'll find that there's not a clear-cut answer to that question as you believe. Furthermore, the proper legal answer will actually vary depending on the jurisdiction.

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Anonymous Coward

Re: the laws of unintended consequences

"Internet purchases are typically made by credit card which are registered to a country."

People, they travel, and carry payment devices with them. If you think that "just tax the credit card" is an easy answer, you're clearly underestimating how complicated those things are.

"Physical goods delivered need a shipping address."

We're talking digital services here. Governments are quite aware of how customs work, and don't really need your insight on that.

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Re: Life's not fair

"Go talk to a lawyer, you'll find that there's not a clear-cut answer"

well ... he would say that, wouldn't he ? His salary depends on you needing him, so he'd have a tendency to make things look more complicated than necessary.

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LDS
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"The tax would benefit countries with large populations"

Which are, incidentally, the same which are damaged more by web giants funneling more money out of them - while a larger population has evidently more social costs that have to be covered by taxes, and if someone doesn't pay, others will be called to fill in. And sincerely, my taxes are high enough already, I prefer Amazon & C. pay their share, even if it means some of my purchases could cost a little more.

Those three countries together are little more than 1/4 of my country population...

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Re: "The tax would benefit countries with large populations"

Those three countries together are little more than 1/4 of my country population...

Which is why it's curious that the article only refers to Ireland, Sweden and Denmark, while ignoring the 4th country which is opposed to this tax on revenue that was proposed by France - Germany. Hardly a small player.

It was discussed on French radio yesterday. The commentator made the point that while Macron is pushing this as a good initiative for the EU, Germany's reluctance is embarassingly blocking it. He added that Brexit will allow the UK to introduce such a tax alone as Hammond has suggested, which is not good for Macron's image.

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LDS
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Re: "The tax would benefit countries with large populations"

Germany has a surplus that makes it less dependent on other revenue streams, and also has a large export surplus that could be threatened if US companies get the US government to retaliate with tariffs on its products and companies. Usual selfish German approach - they can't ask other countries to resolve their debt and slow growth problems while allowing money to fly away, requiring harsher conditions locally. Sure, this won't resolve it and other measures are needed, but this is still part of the problem.

I would also lie to see where local business are impacted more - Germans usually have an higher purchase power than elsewhere (higher wages and lower prices). Countries with high tax rates and higher debt (France, Italy), are obviously much more interested in getting the money which are escaping now.

And still both SPD and CDU are taking big hits at every election...

I wonder if Sweden if part of the group because it fears Ikea will be impacted by the rules.

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Re: "The tax would benefit countries with large populations"

Germany was in favour of the deal. Merkel agreed it with Macron a few years ago. It was one of the few of his suggestions for EU reform that she actually agreed to. I presume they're blocking because of worries about Trump getting difficult.

But Merkel's not always so hot at sticking to her agreements. Though I'm not really up on the politics of why Germany isn't in favour. Is it coalition politics?

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Re: "The tax would benefit countries with large populations"

Though I'm not really up on the politics of why Germany isn't in favour. Is it coalition politics?

Germany wants a worldwide agreement, WTO-level, and isn't in favour of the EU going it alone, as France wants.

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Re: "The tax would benefit countries with large populations"

Phil O'Sophical,

So why did Merkel agree on doing it at the EU level with Macron last year? It's that change I don't understand.

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Re: "The tax would benefit countries with large populations"

So why did Merkel agree on doing it at the EU level with Macron last year? It's that change I don't understand.

Donald Trump happened, I think. Germany is worried about reprisals against its industries if this becomes an EU/US trade war. That seems to be the French interpretation, anyway. I don't read German so I can't check their press, perhaps someone else will have info.

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Re: "The tax would benefit countries with large populations"

Thanks. I guessed it would be, but haven't seen anyone explain it. German politics are a bit fluid at the moment, what with the coalition losing popularity and Merkel announcing she's off - which makes things much harder to follow from a distance.

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aks

Revenue (a.k.a. turnover) is already taxed. It's called VAT.

None of this grandstanding considers the obvious counter-strategies the digital companies will adopt.

All companies with shareholders are duty-bound to minimise their costs. One of the ways to do this is to use the existing laws in legal ways.

Until the OECD including Brussels and Washington can agree on a new taxation strategy there will be no real change.

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VAT

It is effectively transparent to company turnover - stat accounts are all ex-VAT (although you will see a net debtor/creditor for VAT owing). VAT is accounted for on the net of (VAT-able) inputs and outputs so its not a tax on turnover.

It is ultimately paid by the end consumer in the chain for that item.

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Re: VAT

Technicalities aside (looking at the downvoters of OP), 'None of this grandstanding considers the obvious counter-strategies the digital companies will adopt.'. Any arguments?

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As far as I understand, services such as those sold by Google and Facebook (though not Amazon) are zero-rated. If some French company pays Facebook Ireland for an ad, Facebook does not charge for VAT at all, and the French company pays the French VAT rate to France.

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Re: VAT

Of course the tax is ultimately paid by the end consumer of the item. And who the heck else do you imagine is going to end up paying this tech tax, if the EU is dumb enough to pass it?

OP is spot on: VAT, aka sales tax, is the only fair way to tax big companies. A tax on "profits" inevitably ends up with a lot of very fat accountants, and angry headlines in the tabloids about how some billion-dollar business is paying $4.93 in tax.

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Re: VAT

sales tax, is the only fair way to tax big companies

SOME big companies.

I work for a company with a multi billion turnover in a commodity sector with thin margins. We already pay all of our taxes according to law, we have no offshore Dutch-double-Irish-NewJersey-Caymans quad decker sandwich tax arrangements.

As a matter of common sense, corporate taxes should be on profit (if anything, but that's another argument), and the problem here is that a small number of largely American companies are exploiting technicalities to transfer profits. Punish those fuckers, not those who already pay their fair share.

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Devil

Re: VAT

"angry headlines in the tabloids about how some billion-dollar business is paying $4.93 in tax."

that's correct. they do that. And they do that LEGALLY by exploiting all of the loopholes, etc..

YOU would, too, if you could. Right? I know of NO altruistic people who would just bend over and pay out all of that money to a gummint when there's a legal way to get around doing it.

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Re: VAT

Exactly !

It like that hypocrite Warren Buffett - "its so unfair my secretary pays proportionally more tax than I do", yet he has a means of addressing that unfairness by writing a very large cheque to US Treasury's voluntary tax fund "to reduce the national debt"

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Re: VAT

the problem here is that a small number of largely American companies are exploiting technicalities to transfer profits. Punish those fuckers, not those who already pay their fair share.

Please. Who are you kidding? *Every* company employs a number of accountants who, whenever something in the tax law changes, look at how it can improve the company profit margin and minimise tax exposure. It's *not* just 'largely American' companies who do this. Every company does it.

And if the law permits it, it is not 'exploiting a technicality'. It is called 'doing what the law says you must do'. That HMRC (or whichever tax authority) eventually cottons on and goes 'hang on, that's not what we meant', that's not the companies that are at fault, but shoddy law-making.

The Double Irish Dutch Sandwich mechanism only exists because the Dutch tax authorities let it. Why do they let it? Because a little bit (the Dutch 'foundations' that usually make up part of the DIDS are still taxed in the Netherlands but at a virtually nil rate because their 'revenue' is all royalty) of a large pie (the said DIDSes) is still better than *no* slice, or worse, *no* pie at all. The Dutch government knows full well that this mechanism is being subverted to funnel profits away, but that arrangement suits them, until it doesn't, that is.

Ireland has already done its bit and has eliminated the quirk in their law books that allowed the Double Irish (portion of the DIDS) to exist. By 2020, all companies using the Double Irish have to have eliminated them because then it is no longer a legal mechanism that has any tax advantages.

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Re: VAT

"VAT, aka sales tax, is the only fair way to tax big companies. "

VAT and sales tax are completely different things. The whole point of VAT is that it's only paid at the consumer at the end of the supply chain, and thus can not be used to "tax big companies".

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LDS
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VAT, aka sales tax, is the only fair way to tax big companies

You mean taxing the customer - because it's the customer who pays VAT or sales taxes, not the company - is the only way? Companies can't increase prices easily to offset taxes on profits or revenues fully, because it could greatly impact sales. Maybe Apple can, but many others can't.

Nor it looks not paying taxes is making some good cheaper for the customer.

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Re: VAT

VAT is collected from the party that sells the thing. That's a sales tax. Yes, there's some extra accounting that goes into it, designed to make it fairer and avoid accumulating, but the end result is that 20% or whatever it is of the total turnover goes to the treasury.

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Re: VAT

YOU would, too, if you could. Right?

No, because I value morality above profit. Avoiding to pay tax is refusing to take one's share of education, defense, infrastructures and so on. Selfishness and greed destroy societies.

A point of view not shared by the corrupt ones who govern us, if they weren't so corrupt they would have closed all these loopholes a long time ago.

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LDS
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"And they do that LEGALLY"

I don't know how much legal it is, when you pay politicians to build such loopholes into tax codes... loopholes which strangely benefit a few powerful ones, and rarely, if ever, the common people...

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