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Originally Posted by Hugh
My information comes from experience of working with Google, the HMRC Legislation, and discussions with my best friend, who is a Senior Tax Partner (with extensive experience in British and International Tax Law, over 30 years Tax Law experience) with one of the Big Four accountancy firms.
The service they sell is on your desktop, which is in the UK - the data servers aren't in Luxembourg, but holding companies are based there, which negates your assertions. They are based in a low-tax regime, which is why the law was changed - you may not like it, but that's what happened.
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I pointed out the separation of Ireland and Luxembourg. A data centre IS in Ireland and IP fees can go anywhere in the world. Apart from anything else, it just makes sense to pick one destination rather than have to deal with 28 different tax regimes.
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In September 2011, we announced that we would invest €75 million to convert a warehouse on an industrial site in West Dublin into our third energy-efficient data center in Europe. To date, we’ve invested approximately €500 million to build and operate data centers on our Dublin site.
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How would UK tax treat those €500 million costs?