As Brussels Moved A Million Migrants Into The EU,Google Europe Moved $23 Billion To Bermuda Tax Haven In 2017

 

'I am going to test your heart under stress. Listen to what I am shouting. BILLION DOLLAR CORPORATIONS LEGALLY AVOID INCOME TAX.'Image: http://www.cartoonstock.com/

While the virtue – signalling lefties and university brainwashed millennials are creaming themselves over the United Nations Pact On Migration, which they see as a big step towards a borderless world; while they chirrup in unison as usual missing the point of what a borderless world would mean. “Oh those lovely dark skinned people will come by the million to live among us and enrich our culture with their enlightened ways and cultural traditions,” they forget that those enlightened ways and traditions include throwing homosexuals off high buildings, stoning women and publicly beheading adulterers.

Whether they think that is a good or bad thing is a matter of opinion. However other implications of a borderless world are not, and our virtue – signalling compatriots might be horrified to learn what other freedoms of movement a borderless world might facilitate alongside unrestricted movement of people. News of Google’s latest and perfectly legal thanks to progress in globalisation, move to protect its obscene levels of profit from taxation in the European Union involve a financial device known as the Double Irish Dutch Sandwich (DDIS). Be careful not to confuse this with A Dutch Reverse Steamboat, which falls into a very different category of activities.

The DIDS accounting strategy involves using a Netherlands-based subsidiary to shift royalties paid in Europe – Google EU is headquartered in Dublin – to Google Ireland Holdings, the company’s Bermuda-based affiliate. According to a Google filing with the Dutch Chamber of Commerce, the search giant channelled 19.9 billion euros ($22.7 billion) through such a structure to its company in the Bermuda tax haven in 2017, around 4 billion euros ($4.5 billion) more than 2016, Reuters reported.

The arrangement, a variation on the dear old ‘Luxembourg Structure’ allowed Google to reduce its tax bill for operations within the EU to single-digit levels,  roughly one-quarter of the official rate for those tax jurisdictions.

But little can be done about it because, as Google likes to remind us, it is perfectly legal.

“We pay all of the taxes due and comply with the tax laws in every country we operate in around the world,” Google said in a statement.

“Google, like other multinational companies, pays the vast majority of its corporate income tax in its home country, and we have paid a global effective tax rate of 26% over the last 10 years.”‘

The DIDS strategy, which involves an employee of the Netherlands company who works in Dublin, sending invoices for ‘management services relating to royalties on patents,’ to an employee of each national operation in the EU (these employees also work in Dublin.) The national offices (which are pigeon holes in mail drop addresses, the accounts people who deal with the invoices actually work in – you guessed it, Dublin.) Then the accounts department of the Bermuda company, the staff of which all work in Dublin, send an invoice for something vague like ‘financial consultancy relating to royalties on patents’ to European headquarters (in Dublin you may remember,) where it is dealt with by someone who may have handled all the transactions in the chain without ever leaving Dublin. This  allows Google to avoid US income taxes and European withholding taxes. However, thanks to recent changes in Irish law (which followed pressure from the EU), the favorable treatment is slated to end in 2020. That will be a bit of a bugger because they’ll have to move back to Luxembourg. Or maybe not.

The goal of a budgetary proposal in Ireland’s 2015 budget was to shut down the use of so-called “Double Irish” and “Double Irish Dutch Sandwich” structures commonly used by U.S. multinationals, such as Google, Microsoft, and Facebook, among others, to significantly reduce their worldwide effective tax rate on royalties derived from the exploitation of intellectual property .

Because the Irish proposal only addresses revenue from royalties on patents, does it really put an end to the Double Irish structures (with or without the Dutch sandwich) or US corporations exploiting the favourable treatment Ireland offers to hide profits offshore? In a word, No. At least not if your accountants have more brain cells than tits or testicles as the case may be. The same benefits can be achieved by only slightly modifying the existing structures to avoid triggering the new proposed rules, For example by moving Google Europe Holdings (Ireland) Ltd. from Dublin to Google Europe Holdings (Malta) Ltd. whose offices are in …………… Dublin.

The Double Dutch structures are useful for a few reasons. Primarily, Ireland has a 12.5 percent corporate income tax rate for active “trading” income, is English speaking, and is highly educated. Also Ireland uses a management and control standard for determining residency, thus it is possible to protect income earned by the top-tier subsidiary from Irish taxation by placing management in another country (an Irish Non Resident company.)

Thanks to the box checking culture of the US public sector, profits can be entirely avoided by ensuring lower-tier subsidiaries to be disregarded for U.S. tax purposes, because all of the non-U.S. activities are considered to be conducted by a single entity. The only factor that has been altered by the Irish proposals is the residency clause. Under the proposals, moving management and control of an Irish company to a Caribbean nation with which Ireland does not have a tax harmonisation treaty covering corporate residency will no longer achieve the desired objective.  Under the treaty with Malta however, it is possible to form an INR, as under existing structures, with its management and control in Malta. Pursuant to the treaty between Malta and Ireland (which will not be overridden by the new proposal), the INR, though trading solely in Ireland, should be treated as a resident of Malta, and not Ireland (See Article 4(3) of the treaty). Malta does not impose any tax on royalties derived from patents or other intellectual properties.
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Margaret Hodge: Labour’s scourge of tax avoiders is outed as a tax avoider (image source)

Ho hum – one week to go to the election and no news worth reporting, we see pictures of Cameron, looking shiny, Miliband looking confused Clegg looking resigned and Nigel Farage holding a pint of beer.

But there is nothing worth talking about.

Yesterday Cameron announced a tax freeze on Income Tax, National Instrance and VAT. Miliband and Ed balls called it a gimmick (which it was)

A few days ago Miliband announced a reduction in Stamp Duty. Cameron, Osborne and Clegg called it a gimmick because that’s what it was.

Green candidates continued to talk bollocks, SNP candidates continued to talk about when Scotland rules the world and Russell Brand recommended that his followers (who are not voting if they take his recent advice) should support Labour.

UKIP candidates continued to talk about the issues most voters want candidates to talk about but their words of common sense were not reported in the media.

Oh and former Labour Minister and current chair of the Public Accounts committee, Margaret Hodge (nee Oppenheimer), who was Labour’s most vigorous critic of tax avoidance by the super rich was exposed as a tax cheat. A report in The Times which is behind a paywall so check it out second hand at IB Times) reveals that Hodge used the Lichtenstein Disclosure Facility (LDF) to transfer onshore 96,000 shares in a private steel­ trading business established by her father. The LDF is a controversial tax deal established in 2009 enabling the transfer of assets out of the Principality of Liechtenstein, a tiny European country with notably low tax rates, to the UK.

It was created as an incentive for those with undeclared income or unpaid taxes to repatriate their assets by offering preferentially time­-limited tax liabilities, substantially lower penalties and no threat of criminal prosecution.

The Stemcor shares Hodge received in this way in 2011, following the winding­ up of the Liechtenstein Trust, were worth about £1.5 million. Her shareholding was properly declared in the parliamentary register of members’ financial interests, but she has not spoken of offshore vehicles or the LDF.

As Hodge has singled out the LDF system for criticism while using it herself her attitude would seem a tad hypocritical to say the least. But then what else would we expect from a member of Labour, the party that claims it speaks for the working class while really representing the interests of lawyers, tax eaters and ‘the stinking rich’ (including Margaret Hodge (nee Oppenheim).

You will not get to know much about the dodgy tax affairs of Margaret Hodge from mainstream media of course, to report fully the dishonesty and hypocrisy of an elitist might open a massive can of worms.

Tony Benn’s inheritance tax dodge – another leftie hyocrite exposed

Pipe smoking, tax dodging Marxist Tony Benn

Remember the patron saint of loony lefties, Saint Anthony of Wedgewood – Benn, previously known as Viscount Stansgate? Agreeable sort of bloke, pip smokers, great speaker, utterly daft opinions as one would expect from an aristocrat who is so deluded he thinks he understands the working class?

Got him now? …………….. Yeah, he was the one who was ever so keen on redistributing wealth from the rich to the poor, evertbody’s wealth ……………….except his own it turns out.

One think all lefties have in common is their hypocrisy, or if you are one of those people who thinks psychobabble is intelligent, their cognitive dissonance.

You see for all his screeching about how the evil rich should be taxed to penury and legal tax avoidance techniques should be criminalized with the death penalty automatically imposed on anyone guilty of being accused, Benn was no slouch when it came to protecting his own modest fortune from the taxman.

Not that I would blame anyone for using legal means to minimise their tax liability, its the hypocrisy of the wealthy Labour supporters I can’t stand.

from Yahoo finance:

A stalwart of the left, Tony Benn was a critic of tax avoidance measures. As an owner of expensive properties in London and the south of England, it seemed inevitable after his death in March that his family would face a hefty inheritance tax bill.

But now publication of the details of his will coupled with records held by the Land Registry suggests he took practical steps more than a decade ago to reduce the impact of this tax on his heirs.

After the death of his wife in 2000 , the couple’s children appear to have taken on part ownership of the family home, a valuable property in Holland Park, west London. This suggests that some planning had taken place to ensure the children inherited directly from their mother, as opposed to the more normal course of events where the first spouse to die leaves everything to the other, who in turn bequeaths everything to the children on his or her own death.

This latter course is especially the norm when the surviving spouse continues to live on in the property. Mr Benn sold the house only in 2011.

How did the transfer of ownership cut the family’s tax bill?

Assuming the couple owned their assets in equal parts, by giving away her share of the property straight to her children or other heirs, rather than her husband, Mrs Benn would make use of her own, personal tax threshold. In 2000 this was £234,000 per person (today it is £325,000).

If she had simply bequeathed her share to her husband no tax would have been payable by him, as assets passing between married couples are exempt. But, crucially, he would have had more assets to bequeath to his children at his own future death and the benefit of his wife’s personal IHT allowance would have been lost. More tax in total would have been paid.

Read full article and read how you too can dodge death tax legally:

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The stink of hypocrisy is often repulsive but when caused by self – righteous leftys wallowing in their own mire it can be remarkably satisfying to the nostrils.

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