* Posts by Tim Worstal

1366 posts • joined 12 Feb 2008


Forget that rare-earth element crunch – we can now just extract them from industrial waste

Tim Worstal

Re: REEs, as the name suggests, are difficult to find and mine

Very slight correction. Titanium's pretty easy. Well, OK, but to explain.

To get to titania, titanium dioxide, is pretty simple. That's why it costs $400 or so a tonne. Take ilmenite (maybe $50 a tonne, thereabouts) and dissolve in sulphuric. Or, alternatively, add coal, chlorine, and light. Nice exothermic reaction - thus self sustaining - and TiCl is a gas at these temperatures, you can distill it out of the other stuff. For the varied gases solidify again at different temperatures, have a long tube that gradually cools and each one will pop out of the little holes along that temperature gradient. Convert back to TiO2 once separated. Used to be one of ICI's big things, plant still exists - or did 5 years ago - up on Teeside somewhere. Hunter Chemicals now maybe?

OK, a bit more complex but not really. But the point is it's pretty cheap. That's why TiO2 is used for simple and cheap stuff like the white in white paint.

Converting the TiO2 to Ti metal, no, that's expensive. Last I looked, years back, nice Ti metal was $14 to $20 a kg.

Units of Ti are easy and cheap to get. Getting them into the form you actually want can be expensive....

Tim Worstal

Re: Tim Worstall

See a couple of comments above......

Tim Worstal

Re: Landfill

Slight technical point. The REs don't in fact preferentially concentrate in the fly ash nor clinker. Pity but there it is. The germanium concentrates beautifully in the fly ash which is why we get 50% of the world's supply from that source.

Ash will have, around and about, whatever concentration was in the original coal minus the carbon. Which isn't quite enough to produce a viable concentration to extract. A number of US schemes testing this out at present and absent some environmental case - say, cleaning up ash ponds - lifting some of the cost it doesn't work.

Tim Worstal

Re: Hmm fails the Tim Worstall Test.

"TBH the content doesn't seem as well argued or convincing as the more in-depth and thought-provoking analysis he used to present here."

Entirely true, here I was well paid - for which thanks - to do so. There, not so much as yet. Thus volume and rather less in any particular piece.

As to this basic idea. Yes, lots of REs in that waste. I've talked, as part of other work, to a few people looking at it. It's entirely and absolutely possible to extract. Would be a reasonable place to get my beloved scandium. Heap leaching would be a good way. A new and different acid? Sure, might be better, might not be. It's the price of doing it that matters.

One thing, no, they're not saying that this new method is selective. Rather, they started with artificial simulacrums of the real material, each sample doped with an individual RE. Which was then extracted. Using this method on the real stuff would give you a concentrate of all the REs. You can peel off the Sc and Y easily by chemical means. But all the rest have to go through one of those girt big RE plants which cost a $ billion each, minimum.

There's also significant U and Th contamination, as noted above. Which doesn't worry so much, it's the daughter products of their breakdown which do. Radium is not nice stuff and it is indeed in there as a result. Yes, really, I've talked to such people.

The real and actual trick of RE extraction would be to find a new method of doing that separation of the lanthanides. If you could do it on a smaller scale (weird but true) in smaller batches then you could take wastes from a wide variety of industrial processes. Stuff that already exists and is just thrown away today. The problem being that if you need a billion $ plant to do it then you want an input stream that is large enough, homogenous enough, to feed into a billion $ plant. If you've smaller processing plant (s) then you can use smaller batches, more heterogenous ones, as your inputs.

There is a candidate technology to do this but no one really wants to spend $50 million to try it out.

Amazon triples profit to $11.2bn, pays ZERO DOLLARS in corp tax – instead we pay it $129m

Tim Worstal

This is really very easy

"How is that even possible?"

They invested more than they made in profits.


Blighty: We spent £1bn on Galileo and all we got was this lousy T-shirt

Tim Worstal


"I really wish El Reg would let Tim Worstall re-explain his rainbows and unicorns once again in a guest article. Smart guy, but one wonders in this case."

I just think the EU is a terrible system which no one should belong to, let alone us. Entirely an arguable idea but that's where it all stems from. Centralised control of the lives of 500 million people just doesn't seem to work for me.

Chacon a son gout, obviously.

Has anyone seen REM lately? No, we mean rare earth minerals

Tim Worstal

Re: Don't be mean to Dr. Riley - he's only vaguely wrong on one thing

My mistake there. Should be Sc.

Scandium and Yttrium are rare earths but not lanthanides is, I think at least, the distinction. Strontium isn't anywhere near being either. And not is Sulphur, mea culpa.

Tim Worstal

Don't be mean to Dr. Riley - he's only vaguely wrong on one thing

All that's been said about REs so far seems fair enough. It is true that finding a deposit large enough to make it worth exploiting is tough.

But this is to do with the separation process.

Yes, separating the 15 from each other (S and Y are easy with chemical means) requires a girt big plant. Last one built cost a $ billion at least. There's really no great way around this, it just has to be large to cover all the steps. And such a large plant wants a homogenous feed. Thus, natural size of the processing plant is girt big, desiring constant feed, deposit must be girt big.

At which point the conceptual error. Or, OK, the possible error and agreed, this is a little bugbear of mine own. Change the processing method. There are alternatives that are possible. Might even be economic too. No one's really done all that much looking in recent decades - since the, say, 1960s really.

I can think of one method that does work - whether it's economic I don't - and which could be set up to take hetergeneous feedstock. So, we could do the extraction in small lots from all those waste piles and off-feeds from other processes and so on. Which neatly solves our problem of a lack of large scale deposits worth pushing through a traditional plant.

All I need is the odd £20 million to go do the research....oh, all right, I'll test it in a lab first for £50,000 if you insist.

As far as the gender pay gap in Britain goes, IBM could do much worse

Tim Worstal

Re: sample size, outliers, biases

"I get the feeling Tim vanished because..." El Ed desired to spend his editorial budget - as is his absolute right - in a different manner. No complaints from me, that's how the industry works.

Fun discussion of a recent paper:

"Children Hurt Women’s Earnings, but Not Men’s (Even in Scandinavia)

Motherhood is the biggest cause of the gender pay gap. It might take fathers to change that."


Actually, children seem to raise men's pay. In a sexually dimorphic species the arrival of children produces asymmetric responses across genders. Remarkable that really.

Have YOU had your breakfast pint? Boffins confirm cheeky daily tipple is good for you

Tim Worstal

This has all been known for decades

"A major study of Americans has punched another hole in the official British government medical advice that there's no "safe level" of drinking.

The cohort study of around 100,000 individuals found that infrequent drinkers and teetotallers had an increased risk of mortality."

That official advice reached its conclusion by the interesting tactic of not recording the outcome for teetotallers at all. Thus only showing the increasing risk from increasing consumption and neatly excising the higher risk of no consumption.

No, really, that is what they did. The bastards.

No fandango for you: EU boots UK off Galileo satellite project

Tim Worstal

Re: Working as intended


"It would be really interesting to see Worstall's opinion now that the 'leave' vote has been hijacked by zealots who really want to walk away completely. I'd be genuinely interested if he still thinks the UK will be better off crashing out with no deal, than it would just staying in the EU."

I'm one of the zealots. Leave, get out entirely, allow them to sail off to perdition as they so obviously desire. I have no desire for us, nor anyone else, to stay in an organisation that can do something as stupid as the eruo.

There's also been a study on this. Patrick Minford. Revert to WTO rules, our exports to them face those tariffs. We decide to go for unilateral free trade. We don't charge ourselves tariffs upon the things that we desire to import. Essentially, what we did in 1846, Corn Laws and all that.

Net effect is to grow the UK economy by 3%. Yes, grow.

But I really am a zealot. I think the very existence of the EU is a bad idea, that everyone should leave it. And I believe that near whatever the economic arguments about it. Proper, full on, zealotry I'm afraid.

MPs petition for legally binding target of 95% 4G coverage across UK

Tim Worstal

Re: Hmm

I heartily support this idea. Bring back TW!

Tim Worstal

Re: Tim Worstall seems to struggle to know the difference between o2 and Ofcom.

"That is quoted from https://www.theinquirer.net"

Quite so and isn't there a connection to El Reg too? ELR being a split off an upgrade or something?

Mind the gap: Men paid 18.6% more than women in Blighty tech sector

Tim Worstal

Re: Oh please

All most kind but I fear I'm a touch unfashionable under the current editorial dispensation.

If I were to write here on this I'd add in these three facts:

1) We only need two numbers to explain all of the observed gender earnings gap. Mothers make less than non-mothers among women (about 9% for the first child, lesser extra amounts for each subsequent). On average, of course, with all these numbers. Fathers make more than non-fathers among men, about 8% or so. Yes, always controlling for all other factors like age, education and so on.

Sexually dimorphic species - one that started out as hunter gatherers with sexual division of labour - has division of labour in child rearing. Really?

2) The stat being used is of all men and women, part and full time, within each company. Back a decade Harriet Harman and the Fawcett Society started bandying about the pay gap of this unadjusted form, part and full timers together. The Statistics Authority, in the form of Sir Michael Scholar, wrote an open letter insisting they stop. To blend in this manner was extremely misleading and more likely to confuse than inform. One can and should use part time to part time, full time to full time. So, we then get a law insisting reporting is done in the misleading manner, do we?

3) Consider what must be true if this is about discrimination. Women are cheap compared to their skills, talents and output. It is therefore possible to make a fortune by discriminating in favour of hiring that cheaper female talent. Dame Steve did exactly this in the 60s and did make that fortune. No one is doing this today. We must therefore conclude that it isn't about discrimination, even that women are not being underpaid for their output.

Then, the bit in the next comment about women who might have children but don't getting lower pay. Actually (and this is just the way the stat was collected) never married childless women in their 40s enjoy a - small to be sure, 1 or 2% - pay premium over the average male. Lesbians do too, presumably something to do with the lower incidence of children. Interestingly, gay men have a pay gap against them in reference to hetero men. Quite possibly that influence of being or not a father affecting the averages.

Give it a bit more time and we'll have a really interesting piece of research that can be done. Same sex coupledom is clearly becoming more common, as is such same sex couples having children. We will therefore be able to study a population where gender (or even sex) is divorced from primary child carer entirely. Be great fun to see what the pay gap is then.

My bet is that primary child carers would face about the same gap as women do today. Meaning that the gap is about primary child carers nowt else. But then we all do hope for confirmation in the future of our own assertions today, don't we?

Nine Iranians accused of cyber-swiping 30TB+ of blueprints from unis, biz on Tehran's orders

Tim Worstal

Re: Low value research

Take your point, yes, but that's not what is being alleged.


"The members of the conspiracy used stolen account credentials to obtain unauthorized access to victim professor accounts, which they used to steal research, and other academic data and documents, including, among other things, academic journals, theses, dissertations, and electronic books. The defendants targeted data across all fields of research and academic disciplines, including science and technology, engineering, social sciences, medical, and other professional fields."

I do read that as breaching the academic publishing paywalls more than anything else.

Tim Worstal

Re: Low value research

"If 30+TB of data cost $3.4B this implies a cost of about $1 per kB"

That's the DoJ lying through their teeth.

Their claim is that the US universities paid about $3.4 billion for the information. Most of which was actually subscriptions to academic journals, the papers from which the Iranians downloaded.

Loss to the universities, zero. They've still got all the information they started with, still got their subscriptions and haven't paid any more for them.

Loss to the publishers like Elsevier - not, clearly, the nominal cost of the downloaded papers. But rather the loss of revenue from those papers which would have been paid for in the absence of the data theft. Obviously, some sort of sum there but it's not $3.4 billion. Tending towards $0 would be my best guess.

Republican tax bill ready to rescue hard-up tech giants, struggling rich

Tim Worstal

Re: Thomas Claburn - Define Wealthy

Wealth and income is one of those difficult problems to which there is no correct answer. Take our footballer, makes a mint for a decade, then lives off it. If we tax both wealth and income then that pattern of lifetime earnings pays more tax than earning the same total amount over a lifetime but at a lower annual rate.

Is that a fair way to do it? Dunno myself but it is a problem, one with perhaps no right answer.

My own prejudice (and it is prejudice, this is not an economic point, it's a gut feel) is that people on less than median earnings should not be paying income tax. Pigou taxes (carbon, congestion etc) yes, sin taxes yes, VAT even, but not income taxes. Those on above median should be paying for society. There's a limit on how much you can get out of them meaning that government will be smaller than it is now. But, you know, there's prejudice for you.

Re Trump's tax bill. Some bollocks in it, the cut on pass through entities is bollocksy in a bad, bad way. They already pay much less than other forms of business organisation. The personal tax cuts being time limited is a result of the silly way they measure. It's the effect upon the deficit in a decade's time which is used as the benchmark. Thus tax cuts (like some of Bush's) have a roughly decade sunset clause. The clause to benefit Trump - weeeell....that's much more like making sure than an extant break (depreciation on buildings and yes, buildings do depreciate, even if land doesn't) stays on the code rather than inventing something new.

Good stuff too. Doubling the standard allowance takes many more on less than median earnings out of the Federal tax net (which is largely, not exclusively, taxes on incomes, sales and property tax are State or even more local) which accords with my above prejudice. Limiting the mortgage deduction is good. Reducing the state tax allowance is good (for you can deduct your state and local taxes from your taxable income, thus saving your marginal Federal tax rate on what you've paid more locally. This means that high tax states are being subsidised by lower tax ones at the Federal level, shouldn't be happening at all. People want a high tax state in NY? Great, you pay for it, why should Kentucky?).

All of those above are unremittingly good.

There are good arguments either way about the corporate tax cut. The US rate is waaaay too high (even if we're going to commit the mistake of thinking that companies pay tax, rather than the true mixture of shareholders and workers in some portion). You have to add the dividend tax rate (15%) to the corporate income tax rate of 35% (because dividends can only be paid from tax paid profits, that offshore cash etc cannot be used) and standard economics says returns to capital should be taxed lower, not higher, than labour income.

But what's really interesting here is that no economist - not even Paul Krugman who really doesn't like the idea at all - is saying that it won't boost growth. It will. Absolutely. The argument instead is over "How Much?" Some trivial amount we don't care about while the plutocrats make out like bandits (copyright P Krugman) or a substantial amount that will benefit all (Trump and friends and a few others but not many).

If the state and mortgage deductions had been abolished overall I would have supported this as being excellent, whatever else was going on. Limiting them is a benefit but, you know, Meh for the overall.

Li-ion batteries blow up because they breed nanowire crystals

Tim Worstal

Tim whiskers

"Actually this kind of "dendrite" are a well-known cause of short circuits in electronics; similar-ish structures form from solder (especially lead-free solder), "

Tin whiskers, why modern electronics (one of the reasons perhaps) are less reliable.

Firemen fund sues Uber for dousing shares with gas, tossing in a match

Tim Worstal

Err, yes....

But they do have to prove they've lost money as a result. Maybe they have too - but it ain't proven yet, is it, as they've not yet had a down round.....

RIP Stanislav Petrov: Russian colonel who saved world from all-out nuclear war

Tim Worstal

"On the Soviet side, the communist state was so paranoid that earlier that month it had shot down a Korean passenger jet that had accidentally wandered into Soviet airspace,"

I spent a decade as the business partner of the nephew of the bloke who ordered that. Mixed bag, Soviet military types.....

El Reg is hiring an intern. Apply now before it closes

Tim Worstal

Re: Is there Fondue?

They're offering some £9.15 an hour more than most of the media competition.....

Please, pleeeease let me ban Kaspersky Lab from US govt PCs – senator

Tim Worstal

Personally I'd have a look through her campaign funding to see which anti-virus company is paying for this.

$30 million below Parity: Ethereum wallet bug fingered in mass heist

Tim Worstal

Re: Those who don't learn from history

I think I actually said every fraud, scam, and mistake.

Leaked: The UK's secret blueprint with telcos for mass spying on internet, phones – and backdoors

Tim Worstal

Re: Apple meet Corer

Been there since long before my labour was liberated from here.

And there's axes to grind and simple facts. Apple borrows inside the US in order to pay dividends and buy back stock. This means it does not have to repatriate foreign profits and then pay US corporate income tax to do so.

As to whether this is a good idea or not that can be axe grinding. But the simple facts are just that, the simple facts.

Google fumes after US Dept of Labor accuses ad giant of lowballing pay for women

Tim Worstal

Re: Statistically Fair Non-Fairness

Pay varying as a result of life choices is an interesting definition of unfairness.

That I understand words rather than code is obviously unfair given that freelance journos don't earn like coders perhaps? Or is it only unfair if it's because I chose this route?

Tim Worstal

Roughly speaking the problem is that

The two are using different definitions. DoL tends to think that pay should be the same for roughly similar positions. Google for the same positions. Thus both can be right by their own definitions.

So, managers should get paid the same, right? HR managers should be paid the same as coding managers? Well, umm.....OK, managers of those overseeing the Goog Algo itself should get paid the same as the manager of the Doodles? Err, well, ......OK, so managers of Python coders, the managers with the same education, experience and place of work, should be paid the same, regardless of gender (or melanin content, who they try to pick up on date night etc)?

Roughly speaking mind, the DoL is towards the beginning of that cry for equal pay, Google towards the end. Who you think is right about what equal pay should mean is up to you but that is where the argument is.

Facebook, Mozilla and Craigslist Craig fund fake news firefighter

Tim Worstal

The interesting question is what is going to be defined as fake news?

For example, someone claiming that global inequality is increasing. Nope, it ain't, it's falling. Poverty increasing in UK? Nope, relative poverty is, that's inequality, is. Global inequality is falling, within country is rising.

Equally, globalisation only benefits the rich.....nope, the great gainers have been the global poor.

Companies must pay more tax! Companies never carry the burden of any tax.

And so on and so on. A true scrubbing of fake news would produce a very, very, different media.....doubt it will happen though.

Pure Silicon Valley: Medium asks $5 a month for absolutely nothing

Tim Worstal

I find this works better

before reading it can be put to a plethora of uses .. lining for kitty litter, firelighters, mopping up old sump oil ...

Tokyo 2020 Olympic medals to be made from old electronics

Tim Worstal

Re: Calling Tim Worstall

Well, I wouldn't say that I'd specifically go out to get phones to recycle them for the gold. But there are people who do mine them and do so productively.

There're a couple of caveats though.

1) No one metal makes the process worthwhile. If you were doing 80s PCs with 200 nm Au plating on the pins them maybe that would be enough in revenue. And if anyone's got some old analogue telephone switches then it's worth hand clipping them for the gold content (have actually watched this being done).

For modern equipment you want the Sn, Cu, Au out and maybe they'll just about cover your costs. Add in not paying Landfill Tax and you're about there.

It might be possible to go further, take the Ta out, but not much more.

2) The other side of this is what are you allowed to throw away? If, once you've started mulching stuff this becomes chemicals waste or some such, with higher disposal costs, you might well find that landfilling the original phones makes more sense.

It's a delicate balance between the two, revenue and final disposal costs. Can go either way dependent.

What certainly doesn't get paid for is the cost of collecting widely dispersed waste into one place. Paying for that has to come from elsewhere. Could be like this. Or, the people who collect today usually try out those that still work and sell them in poor countries. That's the extra revenue that makes the whole system work. Just recycling for the metals costs will not and cannot pay for the costs of the whole system, including collection.

We're not quitting the UK: Microsoft quashes Brexit fake news

Tim Worstal

Re: Microsoft's 'secret' tax 'deal'

The specific agreement that Microsoft has with HMRC is an "advance pricing agreement."

In layman's terms this is M asking HMRC "Iz we obeying the law?" and HMRC sending back a letter saying "As far as we can see, yes."

This is not an outrage.

Basic income after automation? That’s not how capitalism works

Tim Worstal

Re: Err

No, sorry, not true.

I'm sure someone or other has written an article about it around here too.

Male market working hours have fallen substantially, female market working hours have risen. Male household working hours have fallen, female household working hours have fallen substantially.

Leisure hours for men and women have risen strongly over the past century.

That Keynes and only working 15 hours a week thing has in fact happened. It's the household working hours that have fallen.

Tim Worstal


"Under capitalism, technological progress results in more products, not in more leisure. Factories that improve their efficiency don’t shut down and send workers home early – workers keep the same hours and crank out more goods."

Oddly, the most remarkable change in human life over the past couple of centuries of capitalism has been the massive expansion of leisure time.

The reason being that as we get richer we take some part of our greater wealth as more leisure. The substitution effect.

But then that's what you get when you've philosophers trying to do economics.

Tech fails miserably in Forbes' most innovative companies

Tim Worstal

Obviously I'm a little biased

What with given the past here and the present at Forbes. However:

"Forbes also only included companies that had more than seven years' worth of public financial data and a market value of over $10bn – thereby removing 99 per cent of the companies that do the bulk of the innovation in the world."

That last isn't really quite right. In economic terms we try to make a distinction between invention and innovation. The first is the creation of some new thing. The second is the general improvement of some thing through multiple iterations.

Small companies are generally more inventive than large. And large generally more innovative than small.

A month to save cryptocurrency Ethereum?

Tim Worstal

Re: First as tragedy, then as farce

"Another couple of millennia and they might be reliable."

Australia copies UK's Google tax on 'contrived' dodges

Tim Worstal

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.

Tim Worstal

Thre is a slight problem with this

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.

Britain is sending a huge nuclear waste shipment to America. Why?

Tim Worstal

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.

Calm down, dear: Woman claims sexism in tech journalism

Tim Worstal

Re: I have to admit that

How would anyone know without trying it?

Tim Worstal

I have to admit that

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?

Facebook paid £4k in tax. HMRC then paid Facebook £27k – for ads

Tim Worstal

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.

Wanna buy an MSP? Attenda hangs 'for sale' sign round its neck

Tim Worstal

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?

If you're one of millions using Magento – stop whatever you're doing and patch now

Tim Worstal

Re: You Know What Really Grinds My Gears?

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.

Tim Worstal

Re: You Know What Really Grinds My Gears?

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.

Five reasons why the Google tax deal is imploding

Tim Worstal

Re: @codejunky - So are they breaking the law or not?

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.

Tim Worstal

Re: So are they breaking the law or not?

"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.

Tim Worstal

Re: @codejunky - So are they breaking the law or not?

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?

Tim Worstal

Re: So are they breaking the law or not?

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.

Amnesty International accuses tech giants of battery bastardry

Tim Worstal

Re: Tracking the origin of minerals

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.

Tim Worstal

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.

Eight-billion-dollar Irish tax bill looms over Apple

Tim Worstal

Re: where....

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.


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