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Will Scotland Leave the UK?
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Old 26-04-2019, 10:42   #2881
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by nomadking View Post
What Google "sell" is supplied from ABROAD.

Amazon distribute goods sold by OTHER companies. Those OTHER companies actually pay any corporation tax due. Amazon charges a fee, and tax will be due on that, but the large costs of setting up warehouses etc will eat into the amount of tax due. Just as it would for ANY other business. Amazon UK doesn't "own" any of the products in their UK warehouses. Any Amazon products are owned by an Amazon company based outside the UK.

With a supermarket, a company like Heinz will SELL to Tesco's, cans of baked beans. Heinz pay tax on that, Tesco's pay tax based on the profits of selling those baked beans. If a product Tesco's sells comes from outside the UK, then UK tax WON'T be due on the sale of it to Tesco's.

It's the same way it has ALWAYS been. It's just that the internet and cheapness of transportation makes it easier to operate from abroad, and so the use has increased.
You are under a misapprehension - the services Google sell in the UK are sold and supplied by staff (they currently employ 3,500 in London, going up to 7,000 by next year) at their huge offices in London, but they put the sales through their Dublin Office or Luxembourg Office (depending on what it is).

I know this because I worked with Google for 5 years as one of members of their Education CIO Group.
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Old 26-04-2019, 10:51   #2882
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Re: Will Scotland Leave the UK?

So, watch out for Amazon (Scotland) post sod off day.

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Old 26-04-2019, 10:57   #2883
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Re: Will Scotland Leave the UK?

Scotland will NOT leave the UK. We don't want to leave and also the UK Government will NOT grant the rights to hold another referendum. Sturgeon can do one.
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Old 26-04-2019, 11:10   #2884
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Re: Will Scotland Leave the UK?

The man from Rutherglen said,
Scotland will never be led
To independence,
So in a sentence,
Sturgeon can do one instead.
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Old 26-04-2019, 11:20   #2885
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by Hugh View Post
You are under a misapprehension - the services Google sell in the UK are sold and supplied by staff (they currently employ 3,500 in London, going up to 7,000 by next year) at their huge offices in London, but they put the sales through their Dublin Office or Luxembourg Office (depending on what it is).

I know this because I worked with Google for 5 years as one of members of their Education CIO Group.
The data comes from their Data centres, none of which are in the UK. The ads are "broadcast" from those data centres. Any sales staff are merely selling a service ultimately physically provided from OUTSIDE the UK.

If the data centre and the costs of building and running it occur OUTSIDE the UK, how would they be able to offset those costs against sales? The principle of Corporation Tax is that it's levelled against PROFITS, not sales.

The Ireland & Luxembourg separation will be that the service charge goes to Ireland, and the Intellectual Property part(ie for using the Google software systems) goes to Luxembourg. The income is then taxed by those countries. Once that money has been taxed it can be sent anywhere in the world, including tax havens.

Quote:
Under the new regime, eligible net income from qualifying IP assets benefits from an 80% exemption from income taxes. Consequently, a corporate taxpayer based in Luxembourg Ville with eligible net income will be taxed on such income at an overall (i.e. corporate income taxes plus municipal business tax) effective tax rate of 5.202% in the 2018 tax year. IP assets qualifying for the new regime also benefit from a full exemption from Luxembourg’s net wealth tax.
Eg A common theme in the Music business is to have royalties sent to somewhere like Holland or Luxembourg with lower tax rates for IP. If they bring some of that already taxed money into the UK, it is taxed further to bring it into line as if it had been brought straight into the UK. If left in the Dutch/Luxembourg company, it can then be invested elsewhere from those companies. Profits from those investments will be taxed in Holland/Luxembourg. The total amount available to invest is more that if it had been brought straight into the UK and taxed fully.

Link
Quote:
What two of the other members of the Rolling Stones, Mick Jagger and Charlie Watts, apparently learned was that Richards's near-death experience meant it was time to think about their heirs. For that, the aging rockers turned to a reclusive Dutch accountant, Johannes Favie, whose company, Promogroup, has helped them minimize their tax bills for more than 30 years.
...
Other Dutch shelters that Promogroup has arranged for the three have already paid off handsomely: over the past 20 years, according to Dutch documents, the musicians have paid just $7.2 million in taxes on earnings of $450 million that they have channeled through Amsterdam — a tax rate of about 1.5 percent, compared with the British rate of 40 percent.
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Old 26-04-2019, 11:29   #2886
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by Sephiroth View Post
The man from Rutherglen said,
Scotland will never be led
To independence,
So in a sentence,
Sturgeon can do one instead.
What's that mean to mean??
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Old 26-04-2019, 11:33   #2887
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by Stephen View Post
What's that mean to mean??
Just a humourous variant of your earlier post.
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Old 26-04-2019, 14:33   #2888
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by nomadking View Post
The data comes from their Data centres, none of which are in the UK. The ads are "broadcast" from those data centres. Any sales staff are merely selling a service ultimately physically provided from OUTSIDE the UK.

If the data centre and the costs of building and running it occur OUTSIDE the UK, how would they be able to offset those costs against sales? The principle of Corporation Tax is that it's levelled against PROFITS, not sales.

The Ireland & Luxembourg separation will be that the service charge goes to Ireland, and the Intellectual Property part(ie for using the Google software systems) goes to Luxembourg. The income is then taxed by those countries. Once that money has been taxed it can be sent anywhere in the world, including tax havens.

Eg A common theme in the Music business is to have royalties sent to somewhere like Holland or Luxembourg with lower tax rates for IP. If they bring some of that already taxed money into the UK, it is taxed further to bring it into line as if it had been brought straight into the UK. If left in the Dutch/Luxembourg company, it can then be invested elsewhere from those companies. Profits from those investments will be taxed in Holland/Luxembourg. The total amount available to invest is more that if it had been brought straight into the UK and taxed fully.

Link
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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Old 26-04-2019, 14:53   #2889
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by Hugh View Post
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.
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.

Quote:
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.
How would UK tax treat those €500 million costs?
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Old 26-04-2019, 20:28   #2890
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by nomadking View Post
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.

How would UK tax treat those €500 million costs?
You are using the same arguments they did, and they lost...

https://www.politico.eu/article/uk-t...s-tax-in-2020/

Quote:
The Digital Services Tax (DST), which the Treasury estimates will raise £1.5 billion over four years, will apply a 2 percent levy to revenues derived from the activities of U.K. users of search engines, social media platforms and online marketplaces. It's not an online sales tax but one that targets revenue generated thanks to data collected from users.
Quote:
The Office for Budget Responsibility, the U.K. government’s tax and spending watchdog, confirmed the tax is expected to come from “a handful of large businesses” — mostly relating to advertising revenue and the commissions charged by online marketplaces. It warned that the estimated £400 million a year tax take is highly “uncertain” because of the “data, modeling and behavioral complexities involved.”
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Old 26-04-2019, 20:34   #2891
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by Hugh View Post
You are using the same arguments they did, and they lost...

https://www.politico.eu/article/uk-t...s-tax-in-2020/
If they lost the argument, why are any new rules needed? It actually proves that I and they are correct.
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Old 26-04-2019, 20:37   #2892
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Re: Will Scotland Leave the UK?

Quote:
Originally Posted by nomadking View Post
If they lost the argument, why are any new rules needed? It actually proves that I and they are correct.
They changed the rules to remedy the avoidance - it’s what governments do.

So you and they "won", but our government (and our country) gets the tax revenue - I can live with "losing" like that...
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Old 26-04-2019, 20:53   #2893
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Re: Will Scotland Leave the UK?

Anyone want to explain how this relates to Scottish nationalists or a referendum? I’m confused ...
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Old 26-04-2019, 20:58   #2894
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Re: Will Scotland Leave the UK?

I can't believe people are willingly embracing the idea of Scotland leaving. Just how much of this country are we going to destroy before handing it to future generations?
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Old 26-04-2019, 21:18   #2895
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Re: Will Scotland Leave the UK?

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Originally Posted by Damien View Post
I can't believe people are willingly embracing the idea of Scotland leaving. Just how much of this country are we going to destroy before handing it to future generations?
Little England is very much how it will end up. On a world par with Liechtenstein.
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