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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:11 pm 
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The Marian Finucane Show this AM- the entire panel were adamant that it's not our money and that we won't see a red cent of it. It's a pure political play by the EU Commission in a veiled attack on the US.

The Panel: Michael McDowell - Ind. Senator / former Tánaiste & Minister for Justice, Suzanne Kelly - Tax Lawyer, John McGuiness - FF TD for Carlow Kilkenny, Patsy McGarry - Irish Times Religious Affairs Correspondent & Diarmuid Ferriter - Professor of Modern History, UCD.

Suzanne Kelly was nearly having fits for the 45 minutes this was discussed!
The Panel were into Irexit mode at some staged during the discussion


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:45 pm 
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FreeFallin wrote:
The Marian Finucane Show this AM- the entire panel were adamant that it's not our money and that we won't see a red cent of it. It's a pure political play by the EU Commission in a veiled attack on the US.

The Panel: Michael McDowell - Ind. Senator / former Tánaiste & Minister for Justice, Suzanne Kelly - Tax Lawyer, John McGuiness - FF TD for Carlow Kilkenny, Patsy McGarry - Irish Times Religious Affairs Correspondent & Diarmuid Ferriter - Professor of Modern History, UCD.

Suzanne Kelly was nearly having fits for the 45 minutes this was discussed!
The Panel were into Irexit mode at some staged during the discussion


I am amazed that the studio had the capacity to accommodate the collective egos.

Collective intelligence - probably not an issue judging by the Irexit mode.

Yeah yeah lets tell the EU to fuck off. How smart? And those companies are here because? :roll:

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:48 pm 
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satechi wrote:
yoganmahew wrote:
I guess that provides a political way out?


I am sure Revenue have a thick file on Bertie :o


If you think women can be bad, try scorning a government dept. A1 smart and ballsy move there by Bertie (Another non-accountant :D )

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 9:52 pm 
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For some reason this submission to Gov from Matheson in 2014 is only available as a cached copy ATM. (My emphasis)

Quote:
OECD BEPS Project in an Irish Context – Public Consultation Fiscal Division Department of Finance Government Buildings Upper Merrion Street Dublin 2 By email: bepsconsultation@finance.gov.ie

Our Ref Your Ref 22 July 2014 TJG/JDU/AF

Dear Sirs

BEPS: A time for strategy not tactics This submission is in response to the public consultation paper entitled “OECD Base Erosion and Profit Shifting Project in an Irish Context” issued by the Department of Finance (the “Department”) on 27 May 2014 (the “Consultation Paper”). Matheson is an Irish law firm and our primary focus is representing international companies and financial institutions doing business in Ireland. Our clients include over half of the Fortune 100 companies. We advise seven of the top 10 global technology companies and over half of the world’s 50 largest banks. We are headquartered in Dublin and also have offices in London, New York and Palo Alto. More than 600 people work across our four offices, including 75 partners and tax principals and over 350 legal and tax professionals. We welcome the opportunity to participate in the consultation process as Matheson has been an active participant in the OECD Base Erosion and Profit Shifting (“BEPS”) project at a national and international level.

1 Key messages Ireland could benefit from international reform if the opportunities that such reform presents are realised and domestic legislative changes are enacted in a measured and considered manner. Legislative amendments of a defensive nature prior to completion of the BEPS project would be premature as there needs to be a careful evaluation of the recommendations and guidelines issued by the OECD working groups and clarity on how Ireland’s treaty partners will implement any recommendations within the framework of a coordinated global response to BEPS. No unilateral action should be taken by Ireland. A lack of certainty and clarity in the implementation of BEPS recommendations will create a dangerous situation for taxpayers. We view this as a real risk for Ireland and would caution that it is vital for Ireland that any changes arising from the BEPS project need to be clear and capable of being understood without uncertainty, by all taxpayers.

2 Key points for Ireland

2.1 BEPS: We recognise the significance of the BEPS project in seeking to reform the international tax landscape. As a small open economy that has traditionally relied heavily on foreign direct investment, the outcome of the BEPS project may present certain challenges for Ireland. In our view, Ireland could benefit from international reform if the opportunities that such reform presents are realised and domestic legislative changes are enacted in a measured and considered manner.

2.2 Coordinated Response: We note that the Department wishes to engage interested parties in a discussion on how Ireland’s domestic tax system might best respond to international tax changes. The discussion process should allow the necessary time over the coming months for all interested parties to provide their feedback on how Ireland should deal with issues arising out of the BEPS negotiations and respond to possible reform arising therefrom. Legislative amendments of a defensive nature prior to completion of the BEPS project would be premature as there needs to be a careful evaluation of the recommendations and guidelines issued by the OECD working groups and clarity on how Ireland’s treaty partners will implement any recommendations within the framework of a coordinated global response to BEPS. The various initiatives put forward as part of the BEPS project are proceeding at pace and it will be important for domestic lawmakers to take measured responses to the recommendations which will ultimately be proposed by the OECD. In any case, if the project is completed on schedule we are likely to know the ultimate recommendations relatively quickly (within the next 12 months) and it would be prudent and sensible to delay making any changes until then. The G20 and OECD have recognised the importance of a coordinated response1. Ireland too has recognised that international tax reform requires a coordinated response2. Following last year’s change to the tax residency rules to address “stateless” income, the Minister for Finance was clear that Ireland would not undertake any further unilateral reforms3. We strongly agree with an approach based on transparent coordinated action.

1. See page 10/11 OECD Action Plan on Base Erosion and Profit Shifting – “…the replacement of the current consensus-based framework by unilateral measures, which could lead to global tax chaos marked by the massive re-emergence of double taxation….It is therefore critical that governments achieve consensus on actions…” “The G20 finance ministers called on the OECD to develop an action plan to address BEPS issues in a co-ordinated and comprehensive manner.” 2. See page 14 “Ireland’s International Tax Strategy” – “International tax challenges cannot be addressed at national level alone – we need a coordinated international response.” 3. http://www.independent.ie/business/iris ... -loophole- 29793468.html
Page 3

2.3 Stakeholders: In determining Ireland’s response to international tax changes, there are a range of stakeholders. First and foremost, Ireland’s priority must be the creation and maintenance of employment to further drive sustainable growth in our economy. Ireland also has a responsibility to protect the significant investment made in this country by multinationals, which create employment on the basis of a stable, transparent and competitive tax environment. At the same time, we clearly need to be cognisant of the views expressed by representatives of EU member states, tax treaty partners and other BEPS participant countries. However, in addressing any perceived concerns, Ireland’s tax regime must retain its relative advantages in the face of increasing competition for mobile investment from within and outside the EU.

2.4 Transparency: The G20 finance ministers called on the OECD to develop an action plan to address BEPS issues in a co-ordinated and comprehensive manner. The OECD has a track record of delivering considered, broad based consensus outcomes that work in practice. However, the BEPS project is being undertaken at breakneck speed against a backdrop of tremendous political pressure and unprecedented media coverage (often partisan and misinformed) of multinational tax practices. It is important that external political and media attention does not compromise the transparency of the BEPS project, the outcomes thereof and most importantly, Ireland’s response.

2.5 Credibility: Integrity and credibility to our key stakeholders should shape Ireland’s response. In this context we recommend that Ireland should seek to adhere to the key principles outlined in 3 below. 3 Key Principles to guide the Irish approach Ireland’s international tax strategy is built around three key elements “Rate, Regime and Reputation”4. While the 12.5% tax rate is clearly understood and has been staunchly defended, it is imperative that in seeking to protect Ireland’s reputation among political stakeholders, its reputation within the international business community and the competitiveness of its regime are not compromised.

We believe Ireland should adhere to the following key principles:

3.1 Tax sovereignty: Ireland should remain ready and prepared to determine and shape its own tax policy, subject to EU law and keeping with the spirit of the BEPS project. This means that Ireland should be free to make considered and informed decisions on overall corporate tax strategy in the context of fully formed and agreed reports and recommendations resulting from the BEPS project. More specifically: (i) 12.5% tax rate: The 12.5% corporation tax rate is often equated with tax sovereignty. The ability to determine corporate tax rates is certainly a key aspect of tax sovereignty. However, a competitive regime requires more than a low standard rate of corporation tax. (ii) Arm’s length standard: Ireland needs to support and defend its tax base. Critical to this is that Ireland needs to stand firm on the importance of the arm’s length standard. A rigorous application of the arm’s length standard by tax authorities should provide a reasonable expectation of outcome and stability for taxpayers and tax authorities. Proposals that move away from the arm’s length standard lack clarity and are open to subjective interpretation. Such proposals are likely to favour larger market countries and create uncertainty which will inevitably give rise to instances of double taxation thereby putting significant pressure on the competent authority resources of Ireland and other small countries. (iii) Competitive tax incentives: Ireland needs to introduce further (EU compliant) tax incentives that encourage and support investment, economic growth and job creation. Ireland cannot afford to adopt a defensive posture and become paralysed by the current debate. For over sixty years, Ireland has pursued tax policies focussed on attracting and retaining foreign direct investment across a broad range of industry sectors and has shown the necessary conviction to enact the required policy measures. Unless Ireland continues to innovate, we can expect that our market share of global foreign direct investment will diminish as other countries continue to enhance their regimes even against the backdrop of the BEPS project. Other EU member states that compete with Ireland for international investment already have tax regimes which are at least as competitive as the current Irish tax regime. It is not the case that Ireland has a clear advantage and equally Ireland must not rest on its laurels in the face of increased competition for investment. Within BEPS there is a clear desire to link profit attribution with substance. This could prove to be advantageous for Ireland but only if it enacts the necessary legislative tax measures which will encourage businesses to locate assets and key people functions to Ireland. (iv) Tax treaties: Ireland needs to steadfastly support the terms of its existing tax treaties and to negotiate new tax treaties that reflect the specific trading relationships it has with different countries being cognisant of that fact that it is a small open economy. The purpose of a tax treaty is to facilitate trade and investment. A tax treaty is not a “one size fits all” solution.

3.2 Stability: In times of great change, the international business community places a premium on stability. As Ireland participates in the BEPS process it is more important than ever that Ireland maintains a stable, thoughtful approach to taxation and tax policy. This means making policy decisions that are well informed and purposeful having regard to all stakeholders interests.

3.3 Reputation: Ireland needs to consider its reputation having regard to all stakeholders and ultimately what is best for the Irish economy in terms of sustainable long term growth. Key to this is giving due consideration to the reputation established over many decades with the multinational investment community, which in recent years have proved a vital part of Ireland’s economic recovery. The timing of any possible further changes to Ireland’s corporate residence rules impacts directly on the perceived stability of the Irish tax regime and Ireland’s reputation amongst investors. There is evidently concern at OECD level with international corporate structures where profits are earned by companies resident in jurisdictions where no corporate tax is levied. This is an issue however that will be addressed through Actions 8, 9 and 10 of the Action Plan on BEPS. It may well be appropriate for Ireland to review its corporate tax residence rules in due course once the post-BEPS landscape becomes clearer. Any unilateral move by Ireland would be premature until the position can be assessed at the completion of the BEPS project when there will be more clarity on how reform measures impact other EU member states in particular. Further changes to our residence rules would inevitably raise concerns with international investors that Ireland no longer retains full sovereignty with respect to our own tax affairs, and therefore would create further concerns about Ireland’s long-term stability and viability in the face of external pressure. Acceding to perceived pressure in a very public manner and contrary to the stated position of the Minister for Finance would be viewed as a sign of weakness and uncertainity. We would further add that the concept of management and control is well established and understood by businesses and tax authorities generally.

3.4 Credibility: In order to maintain credibility it is important that stated policy position and actions are aligned. Therefore when the Taoiseach and government ministers state that Ireland will not change the 12.5% tax rate everyone recognises that the rate is settled policy. Equally, when the Minister for Finance says there would be “no unilateral action” in response to BEPS, it is important that any changes required to our tax legislation to address BEPS related matters are only made as part of a coordinated international response.

3.5 Certainty: While it may help in reaching consensus for the BEPS proposals to be drafted in a somewhat subjective manner, ultimately subjective language will be interpreted in a manner that favours larger countries. A lack of certainty and clarity in the implementation of BEPS recommendations will create a dangerous situation for taxpayers. We view this as a real risk for Ireland and would caution that it is vital for Ireland that any changes arising from the BEPS project need to be clear and capable of being understood without uncertainty, by all taxpayers.

3.6 Proportionality: There should not be a presumption that every cross-border transaction by multinationals is an attempt at BEPS. Ultimately, measures proposed or introduced to tackle BEPS should be targeted and must be proportionate.

3.7 Confidentiality: Information sharing between tax authorities is an important tool in combatting [sic - Grumpy] BEPS, but the confidential nature of that information must be respected by all tax authorities. Transparency and the sharing of information should be encouraged as part of the BEPS project, however transparency should also be applied both ways so that taxpayers are also notified when information relating to their tax affairs is shared with other tax authorities.

3.8 Defence of established principles: Ireland as a member of the OECD is fully entitled to participate in discussions and put forward its own views as part of the consensus forming process. The OECD acts by consensus and Ireland’s perspective must be articulated clearly to help shape that consensus going forward. Investors and citizens alike expect the Irish government and its representatives to protect our national interests to the highest degree possible. Ireland’s interests can continue to be safeguarded by ensuring that we continue to have a strong and well-resourced competent authority, adhering to the overall goal of having a stable legal system and tax environment, and importantly through appropriate advocacy and participation in international bodies, such as the OECD. The current international tax principles of source and residence country taxation were formulated nearly 100 years ago. Now, large market economies, with the exception of the US, are seeking to amend these principles in a way that favours their position in the current globalised economy. Ireland is a capital exporting jurisdiction due mainly to the significant investment by multinationals it has attracted over many years so it is important that it defends established taxation principles and resists proposals which unduly favour large consumer economies. In so doing, it will be adhering to taxation principles which are fair and balanced to all economies. We look forward to having the opportunity to further expand upon the issues noted in our submission with you in due course. Yours faithfully Sent by email, bears no signature MATHESON

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 10:04 pm 
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Very interesting backgrounder from 2013 in the WSJ.

Matheson are mentioned numerous times. Without suggesting any wrongdoing at all, I don't think it's an unreasonable conclusion that their advice has pissed off people stateside.

Quote:
The Irish government is targeting a maneuver that Apple Inc. and other companies have used to minimize taxes—a move aimed at countering international criticism but one that some accounting experts say may have little effect on what companies actually pay.

Ireland, whose low corporate income-tax rate figures in many big companies' tax strategies, plans to change rules that businesses use to become "stateless" for tax purposes, the finance ministry said.


http://www.wsj.com/articles/SB100014240 ... 2697448774

ps google "stateless" and "matheson" and you get 35,000 results (a lot with the line through matheson mind - not quite sure how to do the verbatim search with the totals reported). I was talking to a big firm lawyer during the week who told me they had scrubbed their site for 110 promotions. I laughed and noted Arthur's Cock seemed to have done the same but they were still in Google's cache and we laughed :P

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 10:27 pm 
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Apple v Sausages

http://www.bbc.com/news/business-37259278
Quote:
Amazon and Starbucks pay less tax in Austria than a local sausage stall, the country's Chancellor Christian Kern has said in a newspaper interview.
"Every Viennese cafe, every sausage stand pays more tax in Austria than a multinational corporation," Mr Kern told Der Standard.
"That goes for Starbucks, Amazon and other companies," he said.
He added that EU countries with low corporate taxes were undermining the structure of the union itself.
"What Ireland, the Netherlands, Luxembourg or Malta are doing here lacks solidarity towards the rest of the European economy," he said.
He praised the European Commission's recent order that Apple should pay 13bn euros (£11bn) more in tax to Ireland.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 10:45 pm 
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FreeFallin wrote:
Apple v Sausages

http://www.bbc.com/news/business-37259278
Quote:
Amazon and Starbucks pay less tax in Austria than a local sausage stall, the country's Chancellor Christian Kern has said in a newspaper interview.
"Every Viennese cafe, every sausage stand pays more tax in Austria than a multinational corporation," Mr Kern told Der Standard.
"That goes for Starbucks, Amazon and other companies," he said.
He added that EU countries with low corporate taxes were undermining the structure of the union itself.
"What Ireland, the Netherlands, Luxembourg or Malta are doing here lacks solidarity towards the rest of the European economy," he said.
He praised the European Commission's recent order that Apple should pay 13bn euros (£11bn) more in tax to Ireland.

They also don't have the grace to be a proper acronym, he added... though MmmmmNIL...?

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 10:54 pm 
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grumpy wrote:
Very interesting backgrounder from 2013 in the WSJ.
I was talking to a big firm lawyer during the week who told me they had scrubbed their site for 110 promotions. I laughed and noted Arthur's Cock seemed to have done the same but they were still in Google's cache and we laughed :P


Dopey cunts think that 60 days = expiry on the Google Cache and they are in the clear. Some of us, however, remember the turd that was called mop.ie for many years. :D

They left stuff like the links below around naming people like Dualta Counihan and Shay Lydon and Ann Marie Bohan in the three entirely RANDOM linked examples below (and neither of whom had anything to do with Apple may I state) ...and any one of whom could have a sealed RICO indictment awaiting them next time they fly into New York for all I know....and of COURSE I know that these things don't happen to Irish Lawyers normally but the big boys are engaged now so who cares about some functionary in Dublin if they will cop a fast plea to avoid a RICO. :D

In the big boy world with tectonic trade block collisions ongoing.....nobody cares about a few lawyers in Dublin any more. Too much serious money at stake.

https://web.archive.org/web/20111021054 ... k-2011.pdf
https://web.archive.org/web/20111021064 ... -Lydon.pdf
https://web.archive.org/web/20111021065 ... r20AMB.pdf

But given the amount of shit that Matheson AKA mop.ie have left lying around over the years you only need ONE of their staff to sing.......just the one. They then qualify as a 'co operating' witness in the US legal scheme of things and that is enough for our American cousins normally. Anyone who thinks otherwise should look up the name "Scott Rothstein" , Scott was never a mobster.

Will I slosh through Arthur Cooks online footprint at random there Grumpy??? Purely at random.

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 11:11 pm 
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I don't think there is any need to pick on AC. They were all at it. Chasing the fees.

Apart from Eugene Fanning of course (of AC) with his porn obsession. How would he have time?

http://www.independent.ie/irish-news/family-ordeal-is-over-as-lawyer-cleared-of-childporn-charges-26409205.html

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sun Sep 04, 2016 11:31 pm 
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Arthur Cox made their website hard to crawl after 2007 or so, unlike Matheson who left it all out there. :)

Anyway, here is a bit of advice for our politicians. Did anyone know that the first mention of the AAA was in the book of Genesis same as Adam n Eve??

Image

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Mon Sep 05, 2016 12:09 am 
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It is kind of hard not to get annoyed when looking at the machinations of entities here and the firms that "service" them...

Take Global Pfizer Supply. A not unsubstantial undertaking that is in liquidation. It has been since 2014 by EY with no filings since then. But hey, who cares. It's Ireland.

Here is the appointment of the liquidator - nothing since

https://www.scribd.com/document/323006525/Pfizer-Global-Supply-Notice-of-Appointment-of-Liquidator

Here are the last filed accounts - before they transferred the trade to another Pfizer entity

https://www.scribd.com/document/323006526/Pfizer-Global-Supply-Account-Details-2012

They have sales of 887M. Profit of 3,771 and tax of 3,668. What a remarkable endeavour :lol:

KPMG are the auditors, McCann's the solicitors.

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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Mon Sep 05, 2016 10:26 am 
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A former US tax official/tax treaty negotiator on the BBC's 'The World Tonight' mentioned that the Irish Revenue's practice of issuing secret rulings it the manner they did was flawed. He didn't accept the EU Commission decision as justifiable, but he seemed to accept that Revenue's way of doing business was not acceptable.

http://open.live.bbc.co.uk/mediaselector/5/redir/version/2.0/mediaset/audio-nondrm-download/proto/http/vpid/p046cqm9.mp3

I have to say that I find this practice of issuing secret rulings repulsive. Whereas the identify of the parties should be kept confidential and information which could reveal confidential business strategies should be protected, the information/ruling should be redacted or generalised to make the principle of the ruling accessible to all and open to examination and questioning.

Tax Collectors around the world have a difficult time dealing with tax advisers who try to exploit the system and make money out of the system working in unexpected or unintended ways. The State should not actively assist people seeking to commercialise private knowledge of the tax code provided to them by Revenue. The tax code affects all equally and all are entitled to equal knowledge of how it works. If one company asks how a particular provision works then everybody in the country is entitled to the answer. Our constitution provides that justice must be done in public. We are all entitled to know the rules.

The activities of tax advisers can have a very corrosive affect on our society if their motivations and selling point is their ability to assist people in bending and exploiting the rules to defeat the intention of the law, rather than assisting people to comply with the rules. Revenue should not be an active participant in this negative aspect of the industry.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Mon Sep 05, 2016 10:47 am 
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+1 Negative Covenant.

cognitive dissonance - the ability to hold two conflicting thoughts simultaneously.

1. The Revenue did massive (global scale type tax avoidance) side deals with US MNCs; and

2. Michael Martin's assertion that the Irish Government are completely separate from Irish Revenue.

IRISH INDEPENDENT: Apple in Ireland is a major employer and not just an empty shell, by Michael Martin
http://www.independent.ie/opinion/comment/apple-in-ireland-is-a-major-employer-and-not-just-an-empty-shell-35017894.html

Michael Martin wrote:
As part of this, we should demand an acknowledgment of the fact that the Irish Revenue Commissioners, unlike bodies in many countries, works independently of government. It applies the law without reference to ministers or agencies. The Commission is entitled to say that it thinks the Revenue made a legal error; however, no evidence has been presented on this. What it is not entitled to do is to say that this was a decision intended to give unfair state aid to one company.
If you want any evidence Michael, just give Michael Lowry a call:
Image

If the EU is dumb enough to swallow that, they don't deserve the tax.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Mon Sep 05, 2016 3:13 pm 
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For the hard of remembering, what is the link to Michael Lowry in relation to independence of the Revenue Commissioners?

Micheal Martin's line is pitiful. He clearly thinks one of 2 things:
  • ... that he's much smarter than he actually is or...
  • ... that other people are much dumber than they actually are.
when in fact he's forgetting that not everyone is a FF voter.


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 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Mon Sep 05, 2016 7:22 pm 
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observer35 wrote:
The 26% jump in GDP in Q1 2015 was was (almost) all Apple (part above normal GDP growth). Most aircraft leasing comes with offsetting financing, which means that it's net effect on GDP is small. Only the IP (and some IP related stuff), add to the GDP (and GNP) without offsetting financing.

There are (at least) two other very large IPs out there (maybe one is your Pharma company, which we can all guess who that long-standing Irish MNC is), what would also distort the Irish national GDP / GNP, but there have been no discussions - to date - with the State (at least on a formal basis), on whether they will "come home" to Ireland.

I would expect that these two IPs got better tax advice on the implications of showing the world that they were using the EU TP system from a "stateless" location (i.e. with no EU tax treaty). It might have given them pause for thought. They might wait for the 130 page report to come out and see how Apple gets on before doing anything else.

Apple is really screwed, and I think the liabilities are only just starting to for it.

When Apple realises how aggressive it's EU tax advice was, it is going to want to start suing some Dublin advisors.


Being a bit of a data nerd as well as an asshole, I had a good look through the stats today.

11.5B of the increase in GDP was capital expenditure on research and development.

2014 - 9,579
2015 - 20,951

That's not planes, it is an intangible asset. It also attracts a 25% tax credit here. Now there are no obvious changes elsewhere in the stats that would show that this was any kind of transfer from another category. Nor was there any evidence generally of boffins beavering away to more than double the R&D spend in the country.

I even considered whether Iron Man had done an inversion to re-domicile his labs here.

Interestingly, elements of the data are suppressed for "confidentiality" reasons - the sectoral analysis that would be helpful to identify where the increase was focused.

It is not unreasonable at all to conclude that this is more tax shenanigans by big companies to erode the cost of closure of the "stateless" company and the double Irish.

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