Board index » The IRISH PROPERTY BUBBLE » The Republic of Property

Post new topic Reply to topic  [ 307 posts ]  [Go to page]   Previous  1 ... 3, 4, 5, 6, 7, 8, 9 ... 31  Next
Author Message
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 10:37 am 
Offline
Too Big to Fail

Joined: Mar 2, 2007
Posts: 4180
Thanks Obserer35 for that clarification.

BTW, excellent stuff from you.


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 10:42 am 
Offline
Nationalised
User avatar

Joined: Jan 1, 1970
Posts: 23301
yoganmahew wrote:
FTBer wrote:
Interesting...
http://m.rte.ie/news/2016/0902/813591-santander-apple/

More detailed than many an RTE article.

It's a good article alright. I wonder could it be argued that the treatment of IP is also selective?


This bit jumped out...

Quote:
Santander's lawyers argued that multinational companies are different.

They have to work out how to be taxed when products and services are being bought and sold across borders between their subsidiaries, a concept known as Transfer Pricing.

That meant that they should be differentiated when it came to how they were assessed for tax, and that this was why tax rulings - or letters of comfort - were vital.


:nin

_________________
Follow The Pin - https://twitter.com/dailypinster

"Politicians are always realistically maneuvering for the next election. They are obsolete as fundamental problem-solvers." - Buckminster Fuller

"I was comfortable with a couple of banks being married today, instead i wake up and find I'm married to the banks." - Catbear

Image


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 11:05 am 
Offline
Property Magnate

Joined: Oct 12, 2014
Posts: 632
Location: Dublin
Observer35, I also really laughed hard when before the ruling I heard the media spinning out the line of "it'll only be a couple of hundred million fine according to well informed sources".

A bit like the Sect110 scandal, the message was: Move along. Nothing to see here.
Well, that wasn't true, and everyone knew it.

No matter who "the well informed sources" in Gubbernment were, they were probably as useful as asking the local blowhard down the pub....
... which is really the origin, I feel, of many of our politicians.
That or "the canny local teacher" who seemed smart to all the other local gombeens as he propelled himself through the parish with a wink & a nudge.


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 11:44 am 
Offline
Under CAB Investigation

Joined: Apr 30, 2013
Posts: 1648
Pill wrote:
Thanks Obserer35 for that clarification.

BTW, excellent stuff from you.

Thanks Pill

You will also understand from this why Theresa May is going to have to invoke article 50 quite soon, and what her #1 goal will be - to keep Britain inside the EU TP system. As I pointed out on my first post on this thread, without being inside the EU TP system (or a customised version of it), you are not only useless to MNCs, but you are toxic. MNCs will be forced to leave London to re-base in a EU country, where they can get full tax relief on their London costs.
http://www.thepropertypin.com/viewtopic.php?p=889542#p889542

George Osborne was well on his way to making London a Dublin Mk 2. The Brits are used to financial engineering (IOM, Jersey Trusts, PM using BVI) and have bigger hungrier law and tax firms in London. It was the ultimate irony after decades of whining about the EU, an arch-Tory like Osborne (proclaimed Thatcher devotee), suddenly "saw the light" and wanted to remain.

However, as we will see from Margrethe Vestager's report, the EU now realise the trick going on with US MNCs avoiding all EU taxes. The UK have little chance of getting full access to the EU TP system. Best case is that they will get a separate tax treaty bristling with protections around IP re-charging (a draft of the CCCTB initiative), which will kill London as an EU TP hub.

The final "spin" that London will still be the hub, but with smaller local EU offices for pass-porting into the EU is a fantasy - London will be toxic for MNCs are they won't be able to offset costs (and in addition, the main reason to have "jobs" in an EU TP hub like Ireland or the UK is to bolster the "economic" justification behind the IP; when your ability to charge out the IP goes, so does the justification for the jobs). I would say that Vestager's report was a shock in Whitehall.

Image


Last edited by observer35 on Sat Sep 03, 2016 5:19 pm, edited 1 time in total.

Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 4:46 pm 
Offline
Nationalised
User avatar

Joined: May 3, 2007
Posts: 12121
Pill wrote:
Thanks Obserer35 for that clarification.

BTW, excellent stuff from you.


Damn right Pill. Outstanding work by Observer.

Let me broach another angle on this . You may have noticed that Apple/Facebook/Amazon ( which contains Dropbox/Netflix)/Google and Microsoft are frantically building Datacenters in Ireland these days.

There a lacuna in EU VAT rules which allow a country to charge 'collection fees' to another. EG a transaction out of an Irish DC to another VAT Jurisdiction will result in a payment to Ireland and that other country both, until 2018 at least I think and probably thereafter it becomes permanent.

The Irish Vat take is proof of domicile in Ireland for economic activity purposes as I understand. iTunes was based in Luxembourg unlike other Apple activities as Luxembourg VAT is only 15% but I hear it is in Dublin nowadays. While a Luxembourg consumer will still pay 15% VAT on an itunes transaction in an Irish DC I think the Revenue keeps a % of that 15% and not all of it goes to Luxembourg and the Revenue is an agent of every other EU revenue in terms of ensuring the forwarding of the monies collected...minus its own cut. OTOH we pay 23% to iTunes since 2015, not 15% to the Lux Revenue as was the case.

I'm sure VAT will rest a tad, on occasion, on its way out. :)

Someone else might have more on this VAT agreement and the minute details, all EU transactions on Google Play, Facebook and iTunes will be handled in/from Ireland by late 2017, not sure about Netflix.

http://www.revenue.ie/en/tax/vat/guide/ ... vices.html

Quote:
The changes to the place of supply rules are being implemented over a period of 5 years with most changes having come into effect on 1 January 2010. There are changes to the place of supply rules for cultural, artistic, sporting, scientific, educational and entertainment services which came into effect from 1st January 2011, further changes to the rules for hiring out of means of transport which came into effect from 1st January 2013, and there will be a significant change in 2015 regarding the place of supply for Business to Consumer services, which will shift the place of taxation from the place of the establishment of the supplier to the location of the customer.

This section is concerned with the place of supply rules.

_________________
SEO Ireland. SEO Dublin.


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 4:55 pm 
Offline
Nationalised
User avatar

Joined: Jan 4, 2013
Posts: 17351
A question that no Irish media have asked, AFAIK: why did the cabinet need to agree to lodge an appeal by the end of the day yesterday? The full EC ruling isn't even available yet.
Is there a good reason, or is it because Tim Cook told Enda Kenny to do itty Friday?

_________________
— Try, fail, understand, win. —


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 5:01 pm 
Offline
Nationalised
User avatar

Joined: May 3, 2007
Posts: 12121
Mantissa wrote:
A question that no Irish media have asked, AFAIK: why did the cabinet need to agree to lodge an appeal by the end of the day yesterday?

Because Microsoft Facebook Google and Amazon expect the Irish Government to protect them too. Think of all the children Mantissa. :)

It was the US Senate wot nabbed Apple, the EU Commission merely clarified some aspects of what they found out in reaching their decision.

_________________
SEO Ireland. SEO Dublin.


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 6:18 pm 
Offline
Too Big to Fail

Joined: Feb 21, 2008
Posts: 4435
When the IRS gets their teeth into this, sooner or later, the really interesting question is when will the IRS start using some of the laws passed back in the 1960's and 1970's against tax shelter vehicles, extensively prosecuted at the time, which all became moot post 1982/86. In Apples case pretty much every single last bit of i.p was created in Cupertino. Its not like they have the wriggle room that MS and Google have with their international dev centers. Even though all the important stuff is still done in Redmond and Mountain View. Given some of the case law from back in the 1970's regarding professional services companies trying to reassign income to third party low tax structures if the IRS ever decided to prosecute the offshoring of i.p then Apple really are toast. There are double penalties on that kind of stuff so that few hundred billion offshored would very quickly disappear in penalties and fines.

This show is going to run and run..


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 7:18 pm 
Offline
Of Systemic Importance

Joined: Jun 9, 2008
Posts: 7098
Absolutely this show will run and run.

How many times have we been frightened by electoral candidates in the US promising to deal with offshore profits? Yet when Apple get threatened by the EU, the White House weighs in.

Nothing changes.

Henry Temple, 3rd Viscount Palmerston noted to the House of Commons in 1848 that

Quote:
as the eternal ally or the perpetual enemy of England. We have no eternal allies, and we have no perpetual enemies. Our interests are eternal and perpetual, and those interests it is our duty to follow... And if I might be allowed to express in one sentence the principle which I think ought to guide an English Minister, I would adopt the expression of Canning, and say that with every British Minister the interests of England ought to be the shibboleth of his policy.


https://en.wikiquote.org/wiki/Henry_Tem ... Palmerston

Nicked by that C*** Henry Kissinger

Quote:
America has no permanent friends or enemies, only interests



_________________
“Don't ask the barber if you need a haircut—and don’t ask an academic if what he does is relevant.” Nassim Nicholas Taleb


Top
 Profile  
 
 Post subject: Re: Apple, Ireland, EU, Tax Avoidance, Margrethe Vestager, C
PostPosted: Sat Sep 03, 2016 7:40 pm 
Offline
Nationalised
User avatar

Joined: May 3, 2007
Posts: 12121
Matheson promise a corporation tax rate of only 2.5% using their special 'structures', bless em .

Image

From > http://www.matheson.com/images/uploads/ ... h_2013.pdf

_________________
SEO Ireland. SEO Dublin.


Last edited by 2Pack on Sat Sep 03, 2016 7:48 pm, edited 1 time in total.

Top
 Profile  
 



Display posts from previous:  Sort by  
Post new topic Reply to topic  [ 307 posts ]  [Go to page]   Previous  1 ... 3, 4, 5, 6, 7, 8, 9 ... 31  Next

    Board index » The IRISH PROPERTY BUBBLE » The Republic of Property

Who is online

Users browsing this forum: Google Feedfetcher, Inis Man and 15 guests


You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum

Jump to:  

Follow, Retweet @dailypinster



Pyramid Built, Is Better Built! - Latest Property Discussions www.thepropertypin.com