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-   -   UK & EU Agree Post-Brexit Trade Deal (https://www.cableforum.uk/board/showthread.php?t=33708171)

jfman 19-09-2019 17:28
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by OLD BOY (Post 36010800)
Your point being? I voted Brexit, but the directive most certainly doesn't affect me.

The correlation is ridiculous and typical of the mud slinging that the remainers are throwing at the Brexiteers as they become more and more desperate to overturn the democratic vote.

Shame on all their houses.
It's hardly ridiculous to assert that campaigners and certain media outlets had significant vested interest against the upcoming EU tax directive. It's a clear fact.

nomadking 19-09-2019 17:58
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010807)
It's hardly ridiculous to assert that campaigners and certain media outlets had significant vested interest against the upcoming EU tax directive. It's a clear fact.
The original directive is from 2016.

The UK ALREADY has similar laws in place and therefore.
Link
Quote:
The changes included here implement the provisions of the ATAD. It applies to all taxpayers that are subject to corporate tax in one or more member states of the EU and deals with exit taxes on unrealised Capital Gains on assets transferred out of the tax jurisdiction
...
This measure is expected to have a negligible impact on the Exchequer.
Link
Quote:
The level of revenue accrued to the public purse as a result of the implementation of Article 5 of the EU Anti-Tax Avoidance Directive (Directive (EU) 2016/1164 of the European Parliament) is expected to be negligible. The UK already has comprehensive exit taxation rules, and the changes necessary to implement the directive are relatively minor and primarily of an administrative nature.

jfman 19-09-2019 18:02
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by nomadking (Post 36010809)
The original directive is from 2016.

The UK ALREADY has similar laws in place and therefore.
Link
Link
Original, not updated.

Similar, not identical.

nomadking 19-09-2019 18:26
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010810)
Original, not updated.

Similar, not identical.
Still fulfils EU rules with the impact being NEGLIGIBLE, ie virtually nothing.

The UK has an agreement with the Netherlands that came into force in 2011 and with Luxembourg from 1968!

Link
Quote:
Multilateral convention to implement tax treaty related measures to prevent base erosion and profit shifting
...
The UK signed the Multilateral Instrument (MLI) in Paris on 7 June 2017 and deposited its instrument of ratification and final list of reservations and notifications on 29 June 2018.
The MLI will enter into force for the UK on 1 October 2018 and will begin to have effect in the UK for UK tax treaties from:
Basically arrangements have been made with various EU and non-EU countries, outside the EU jurisdiction long before now.

We even have arrangements with Albania.
List of Countries

jfman 19-09-2019 18:36
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by nomadking (Post 36010811)
Still fulfils EU rules with the impact being NEGLIGIBLE, ie virtually nothing.

The UK has an agreement with the Netherlands that came into force in 2011 and with Luxembourg from 1968!

Link
Basically arrangements have been made with various EU and non-EU countries, outside the EU jurisdiction long before now.

We even have arrangements with Albania.
List of Countries
Irrelevant. They don’t want us to adhere to soon to be implemented EU rules. Negligible can be different enough.

What about UK offshore tax havens?

The legislation could match 99.99% and still leave loopholes for the previously mentioned group.

nomadking 19-09-2019 18:56
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010813)
Irrelevant. They don’t want us to adhere to soon to be implemented EU rules. Negligible can be different enough.

What about UK offshore tax havens?

The legislation could match 99.99% and still leave loopholes for the previously mentioned group.
The UK introduced laws BEFORE the EU got involved. That is why implementing the EU rules will have a negligible impact.

This is about where money is transferred between countries. Eg earned in Albania but transferred to the UK. Any tax paid in Albania is taken into account when calculating the UK tax due. If it remains in Albania, then it is nothing to do with the EU or anybody else, just Albania.

Money transferred from the UK to a tax haven will already have been taxed in the UK. Any profits the business in the Tax haven makes, are subject to that countries rules only. It is when any profits are transferred back to the UK, it becomes liable for UK tax.


Money invested in a tax haven hedge fund will have already been taxed in the originating country. Money that is earned by the hedge fund will be taxed according to the tax haven rules. But when profits are sent back to the investors they will be subject to the rules of their country.

OLD BOY 19-09-2019 19:03
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010807)
It's hardly ridiculous to assert that campaigners and certain media outlets had significant vested interest against the upcoming EU tax directive. It's a clear fact.
Except that it implies that this is their motivation, whether good for the country or not.

I like eating turkey in the festive season, but that is not the reason I like Christmas.

jfman 19-09-2019 19:04
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by nomadking (Post 36010814)
The UK introduced laws BEFORE the EU got involved. That is why implementing the EU rules will have a negligible impact.

This is about where money is transferred between countries. Eg earned in Albania but transferred to the UK. Any tax paid in Albania is taken into account when calculating the UK tax due. If it remains in Albania, then it is nothing to do with the EU or anybody else, just Albania.

Money transferred from the UK to a tax haven will already have been taxed in the UK. Any profits the business in the Tax haven makes, are subject to that countries rules only. It is when any profits are transferred back to the UK, it becomes liable for UK tax.

Money invested in a tax haven hedge fund will have already been taxed in the originating country. Money that is earned by the hedge fund will be taxed according to the tax haven rules. But when profits are sent back to the investors they will be subject to the rules of their country.
Again none of this is relevant in the context of wanting to avoid a similar but not identical EU directive that closes further loopholes.

They’re rational capitalists - of course they want different rules.

---------- Post added at 19:04 ---------- Previous post was at 19:03 ----------

Quote:
Originally Posted by OLD BOY (Post 36010815)
Except that it implies that this is their motivation, whether good for the country or not.

I like eating turkey in the festive season, but that is not the reason I like Christmas.
Rational capitalists seek to income maximise. The good of the country is irrelevant.

nomadking 19-09-2019 19:09
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010816)
Again none of this is relevant in the context of wanting to avoid a similar but not identical EU directive that closes further loopholes.

They’re rational capitalists - of course they want different rules.

---------- Post added at 19:04 ---------- Previous post was at 19:03 ----------



Rational capitalists seek to income maximise. The good of the country is irrelevant.
If we remain in the EU:mad:, then NOTHING will have to be changed. It is STILL compliant with the EU directive, (for the most part) BEFORE the directive even existed.

jfman 19-09-2019 19:12
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by nomadking (Post 36010819)
If we remain in the EU:mad:, then NOTHING will have to be changed. It is STILL compliant with the EU directive, (for the most part) BEFORE the directive even existed.
Original version, not the updated one. “For the most part” does not mean in entirety. You literally cannot win this argument you conceded defeat with your own carefully nuanced language.

nomadking 19-09-2019 19:29
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by jfman (Post 36010820)
Original version, not the updated one. “For the most part” does not mean in entirety. You literally cannot win this argument you conceded defeat with your own carefully nuanced language.
Quote:
The UK already has comprehensive exit taxation rules, and the changes necessary to implement the directive are relatively minor and primarily of an administrative nature.
Just more paperwork involved.

If I set up a company in France, then any profits are initially taxed to FRENCH rules. If I keep the money there and use the company to make investments in France, then it is nothing to do with UK authorities. If I then pay myself a "dividend", that would be subject to UK tax, taking into account the tax already paid in France.

NO TAX HAS BEEN AVOIDED.


This is an example of tax avoidance.
Quote:
Jeremy Corbyn failed to declare a third pension on his HMRC tax form, it has emerged, as he refused to disclose documents regarding his full tax declaration last night.
Following the Labour leader's admission that he neglected to include his state pension or previous local government pension on his tax return, a spokesman for Mr Corbyn said yesterday that a third pension was also missed off the official document.

jfman 19-09-2019 19:35
Re: Brexit Development(s) Discussion
 
“primarily of an administrative nature.”

Primarily doesn’t mean exclusively. If you were leaving a tax loophole open for your friends you aren’t likely to put it in the consultation.

More nuanced language.

If tax was as simple as you state why do tax havens exist at all???

I told you that you literally cannot win here. You clearly don’t understand the complexity of tax loopholes.

I don’t see why you are deflecting Corbyn into this. It’s irrelevant to the point under discussion although I can understand your frustration at losing it fairly embarrassingly.

Hugh 19-09-2019 19:37
Re: Brexit Development(s) Discussion
 
Quote:
Originally Posted by nomadking (Post 36010821)
Just more paperwork involved.


If I set up a company in France, then any profits are initially taxed to FRENCH rules. If I keep the money there and use the company to make investments in France, then it is nothing to do with UK authorities. If I then pay myself a "dividend", that would be subject to UK tax, taking into account the tax already paid in France.


NO TAX HAS BEEN AVOIDED.
HMG seem to think differently...

https://www.gov.uk/government/public...ance-directive
Quote:
Two specific changes are being made to the UK CFC rules which will improve the protection they provide. These changes relate to the definition of control, and the treatment of certain profits generated by UK activity. These changes will make sure that the UK CFC rules comply with Council Directive (EU) 2016/1164, ATAD.
Quote:
This measure introduces 2 changes to the UK Controlled Foreign Company (CFC) regime.

The first change expands the scope of the control rules, which determine whether or not a non-UK resident entity falls within the UK CFC regime.

The second change restricts the scope of the full and partial exemption rules for finance profits, so that these exemptions are not available to the extent that key activities which generate such profits have been carried out in the UK.
Quote:
This measure is expected to impact on large multinational groups, with one or more UK tax resident companies, through introducing 2 changes to the UK CFC regime. One-off costs included familiarisation with these changes.

jfman 19-09-2019 19:40
Re: Brexit Development(s) Discussion
 
Oh Hugh get out of here with facts, they’re not welcome.

Hugh 19-09-2019 19:43
Re: Brexit Development(s) Discussion
 
And the reason for these changes...

https://www.theneweuropean.co.uk/top...f-eu-1-5669763

Quote:
The directive seeks to tackle the thriving culture of corporate tax avoidance. For example, consider the scenario in which an EU company shifts profits to a related company in a low-tax country reducing the tax paid on these profits: under ATAD, a company could still do this, but the profits will be taxable at EU rates.

Another situation is where EU businesses developing a new product move it to a low tax country to avoid paying larger taxes on the profits once it is developed. Thanks to ATAD this tactic won’t work as member states can levy tax on the product before it is moved.

Even with ATAD, you might argue companies – through their nifty lawyers – will find new loopholes to avoid tax, right? The EU thought of that: ATAD provides a general anti-abuse rule to counteract these regimes where national laws have failed to address them.
I asked my friend* (who is a Tax Partner with one of the "Big 4" about these changes, and he thinks they are a good idea, and will discourage the behaviours listed above.

*we are also god-parents to each others children, and go on holiday together (next year is a Florida road trip...


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