Will the G8/Tax Law Changes screw the 26's Competitive Corp Tax Advantage?

Started by theskull1, May 21, 2013, 12:10:53 AM

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glens abu

Quote from: mayogodhelpus@gmail.com on May 23, 2013, 11:45:22 PM
Quote from: glens abu on May 23, 2013, 11:42:09 PM
Quote from: mayogodhelpus@gmail.com on May 23, 2013, 11:37:56 PM
O'Dowd an enemy of the Republic. This should be shown to Irish voters, watch SF disappear in the 26.

Just agrees in equality but sure you would know feck all about that,squeeze the pleb for all he is worth but let the big lads cheat.Is that what the men of 16 died for.Republic my arse.



No, SF lunacy to add tens if not hundreds of thousands to the dole queue. Economic terrorists.

So you would be happy if they allowed apple to pay no tax even if all other companies and the people were being crippled with tax demands?

Syferus

Political parties will chose to oppose anything if they think it'll appeal to voters. Morals don't really come into it. Not a topic for Sinn Fein's usual posturing.

armaghniac

QuoteThat they are allowing apple to pay 2% instead of 12.5% CT

But there are not, Apple is paying 12.5% on anything taxable.
If at first you don't succeed, then goto Plan B

theskull1

Quote from: armaghniac on May 24, 2013, 12:12:35 AM
QuoteThat they are allowing apple to pay 2% instead of 12.5% CT

But there are not, Apple is paying 12.5% on anything taxable.

Its been mentioned that there have been special deal made with the big corporations (small percentage of a large amount is better than a large percentage of nothing being the argument made by these companies)
It's a lot easier to sing karaoke than to sing opera

glens abu

Quote from: armaghniac on May 24, 2013, 12:12:35 AM
QuoteThat they are allowing apple to pay 2% instead of 12.5% CT

But there are not, Apple is paying 12.5% on anything taxable.

Well if thats the case thats fine,all John O'Dowd was saying if that is not the case then its wrong.

Hound

Quote from: theskull1 on May 24, 2013, 01:00:45 AM
Quote from: armaghniac on May 24, 2013, 12:12:35 AM
QuoteThat they are allowing apple to pay 2% instead of 12.5% CT

But there are not, Apple is paying 12.5% on anything taxable.

Its been mentioned that there have been special deal made with the big corporations (small percentage of a large amount is better than a large percentage of nothing being the argument made by these companies)
There is no "special deal".

We should not be believing what US or UK politicians are saying. They are speaking half truths in order to gain publicity. Their main objective is most usually to ensure they will be voted in by whoever their constituients are in their next election.

Of course subsidaries of multi-national companies will pay out royalties to wherever the IP is held. If these royalties were being paid out to the US, there wouldnt be a word about it. But because years ago the Apples and Googles have transferred their IP out to Bermuda or Cayman Islands or wherever (which they did legally and would have got approval from the infamous IRS in the US on the valuation of the IP at that time, and they would have been subject to US tax on the transfer) there now is uproar.

This is a US tax issue, not an Irish tax issue. There is no Irish tax avoidance. We completely and transparently follow international tax best practice as presctibed by the OECD. But its gas how many Irish begurdgers are jumping on this bandwagon to put the boot in.

Declan

QuoteWe completely and transparently follow international tax best practice as prescribed by the OECD

I think that's the nub of the issue alright. Irrespective of the politicians in either country do we want to be known as this type of tax haven along with Netherlands , Luxembourg etc

Interesting article here - http://www.independent.ie/opinion/analysis/elaine-byrne-ifsc-living-by-its-own-rules-and-not-in-the-real-world-26850576.html

johnneycool

Quote from: Declan on May 24, 2013, 12:34:15 PM
QuoteWe completely and transparently follow international tax best practice as prescribed by the OECD

I think that's the nub of the issue alright. Irrespective of the politicians in either country do we want to be known as this type of tax haven along with Netherlands , Luxembourg etc

Interesting article here - http://www.independent.ie/opinion/analysis/elaine-byrne-ifsc-living-by-its-own-rules-and-not-in-the-real-world-26850576.html

If apple did a deal, why didn't Boner and the boys in U£?

Main Street

Quote from: Hound on May 24, 2013, 10:09:36 AM
Quote from: theskull1 on May 24, 2013, 01:00:45 AM
Quote from: armaghniac on May 24, 2013, 12:12:35 AM
QuoteThat they are allowing apple to pay 2% instead of 12.5% CT

But there are not, Apple is paying 12.5% on anything taxable.

Its been mentioned that there have been special deal made with the big corporations (small percentage of a large amount is better than a large percentage of nothing being the argument made by these companies)
There is no "special deal".

We should not be believing what US or UK politicians are saying. They are speaking half truths in order to gain publicity. Their main objective is most usually to ensure they will be voted in by whoever their constituients are in their next election.

Of course subsidaries of multi-national companies will pay out royalties to wherever the IP is held. If these royalties were being paid out to the US, there wouldnt be a word about it. But because years ago the Apples and Googles have transferred their IP out to Bermuda or Cayman Islands or wherever (which they did legally and would have got approval from the infamous IRS in the US on the valuation of the IP at that time, and they would have been subject to US tax on the transfer) there now is uproar.

This is a US tax issue, not an Irish tax issue. There is no Irish tax avoidance. We completely and transparently follow international tax best practice as presctibed by the OECD. But its gas how many Irish begurdgers are jumping on this bandwagon to put the boot in.
There is Irish tax avoidance with this tax avoidance scheme. The corporation tax is paid in Ireland by the corporations who are registered as domiciled in Ireland, after the royalties are deducted from the profits. It's even commonly known as the 'Double Irish'.

Hound

Quote from: johnneycool on May 24, 2013, 01:29:57 PM
Quote from: Declan on May 24, 2013, 12:34:15 PM
QuoteWe completely and transparently follow international tax best practice as prescribed by the OECD

I think that's the nub of the issue alright. Irrespective of the politicians in either country do we want to be known as this type of tax haven along with Netherlands , Luxembourg etc

Interesting article here - http://www.independent.ie/opinion/analysis/elaine-byrne-ifsc-living-by-its-own-rules-and-not-in-the-real-world-26850576.html

If apple did a deal, why didn't Boner and the boys in U£?
We definitely don't want to be a tax haven and mentioned in the same breath as Bermuda, Cayman, Jersey. But there's nothing wrong with being in the same bucket as Netherlands and Luxembourg - they are the EU countries we are in most competition with in order to attract MNCs. I wouldnt class either of those or us as tax havens, but we are definitely more transparent than them (they do have special negotiated deals with different companies). Also we have more strict substance requirements than either of those (particularly Lux) - if you have a new company you need to have at least a small number of employees involved in the running of the business in order to obtain the 12.5% rate. The brass nameplate won't suffice.

Ireland can't introduce the FTT until the UK do. We'd be handing them a hige competitive advantage, that would cost a lot more than the supposed tax revenues we're losing out on.

Apple didnt do a deal. Apple pays tax at 12.5% on Irish profits.   

Hardy

I don't know why people are wringing their hands about damage to our reputation. The IDA couldn't buy publicity like this - coast-to-coast on prime time.

armaghniac

QuoteIreland can't introduce the FTT until the UK do. We'd be handing them a hige competitive advantage, that would cost a lot more than the supposed tax revenues we're losing out on.

Exactly, no transactions  would be done in Ireland, everything would be in London.
It isn't rocket science. 
If at first you don't succeed, then goto Plan B

Hound

Quote from: Main Street on May 24, 2013, 03:48:58 PM
There is Irish tax avoidance with this tax avoidance scheme. The corporation tax is paid in Ireland by the corporations who are registered as domiciled in Ireland, after the royalties are deducted from the profits. It's even commonly known as the 'Double Irish'.
Yip, the so called double Irish is something I am very familiar with - but there is absolutely no Irish tax avoidance here.

Royalties are proper business expenses. They have to be paid. You have to pay for IP you use that belongs to some other entity. The fact that companies have moved their non-US IP out of the US is absolutely nothing to do with Ireland. The movement of this IP was 100% legal and subject to tax in the US.

There is certainly a bit of a gimmick going on by companies whereby they sometimes use Irish incorporated companies that are tax resident outside Ireland (e.g in a haven). Ireland has no right to tax companies which are not resident here or have no Irish operations here, as would be the case with those companies.

The MNCs use such companies so they don't have to publish in their accounts that they have entities in Bermuda, Cayman, etc, because they are afraid that might look bad. Its sneaky, no doubt about that. But its absolutely not tax avoidance and its not a secret to either the IRS or the Irish Revenue.   

Main Street

Quote from: Hound on May 24, 2013, 04:06:20 PM
Quote from: Main Street on May 24, 2013, 03:48:58 PM
There is Irish tax avoidance with this tax avoidance scheme. The corporation tax is paid in Ireland by the corporations who are registered as domiciled in Ireland, after the royalties are deducted from the profits. It's even commonly known as the 'Double Irish'.
Yip, the so called double Irish is something I am very familiar with - but there is absolutely no Irish tax avoidance here.

Royalties are proper business expenses. They have to be paid. You have to pay for IP you use that belongs to some other entity. The fact that companies have moved their non-US IP out of the US is absolutely nothing to do with Ireland. The movement of this IP was 100% legal and subject to tax in the US.

There is certainly a bit of a gimmick going on by companies whereby they sometimes use Irish incorporated companies that are tax resident outside Ireland (e.g in a haven). Ireland has no right to tax companies which are not resident here or have no Irish operations here, as would be the case with those companies.

The MNCs use such companies so they don't have to publish in their accounts that they have entities in Bermuda, Cayman, etc, because they are afraid that might look bad. Its sneaky, no doubt about that. But its absolutely not tax avoidance and its not a secret to either the IRS or the Irish Revenue.
A bit of a gimmick!!!
If this is not regarded as a tax avoidance scheme by you, then what is?  Just because the scheme is legal doesn't mean it's not a tax avoidance scheme.
It fulfils every criteria to be called a tax avoidance scheme. Experts on tax avoidance schemes all around the world are calling this, a tax avoidance scheme.


lawnseed

Quote from: Main Street on May 25, 2013, 12:20:43 AM
Quote from: Hound on May 24, 2013, 04:06:20 PM
Quote from: Main Street on May 24, 2013, 03:48:58 PM
There is Irish tax avoidance with this tax avoidance scheme. The corporation tax is paid in Ireland by the corporations who are registered as domiciled in Ireland, after the royalties are deducted from the profits. It's even commonly known as the 'Double Irish'.
Yip, the so called double Irish is something I am very familiar with - but there is absolutely no Irish tax avoidance here.

Royalties are proper business expenses. They have to be paid. You have to pay for IP you use that belongs to some other entity. The fact that companies have moved their non-US IP out of the US is absolutely nothing to do with Ireland. The movement of this IP was 100% legal and subject to tax in the US.

There is certainly a bit of a gimmick going on by companies whereby they sometimes use Irish incorporated companies that are tax resident outside Ireland (e.g in a haven). Ireland has no right to tax companies which are not resident here or have no Irish operations here, as would be the case with those companies.

The MNCs use such companies so they don't have to publish in their accounts that they have entities in Bermuda, Cayman, etc, because they are afraid that might look bad. Its sneaky, no doubt about that. But its absolutely not tax avoidance and its not a secret to either the IRS or the Irish Revenue.
A bit of a gimmick!!!
If this is not regarded as a tax avoidance scheme by you, then what is?  Just because the scheme is legal doesn't mean it's not a tax avoidance scheme.
It fulfils every criteria to be called a tax avoidance scheme. Experts on tax avoidance schemes all around the world are calling this, a tax avoidance scheme.
richard murphy tax research describes ireland as a 'tax tart hitchin up her shirt to attract punters' cant help picturing edna in drag :D
A coward dies a thousand deaths a soldier only dies once