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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Theresa May’s New Contempt Of Parliament Scandal

On a day that saw her government defeated three times in House of Commons votes on key Brexit issues, a new scandal has erupted around Theresa May’s dishonest and duplicitous  mismanagement of the Brexit process. The Prime Minister has now been accused of holding secret weekly Brexit meetings with pro EU Cabinet ministers and civil servants of which no record has been made, sparking accusations of a “conspiracy to derail Brexit”.

Political advisers to the Government are said to have been increasingly concerned about the meetings especially as May has increasingly sidelined elected MPs on her negotiating team and delegated responsibility for negotiations to rabidly pro EU civil servants such as Oliver ‘Oily’ Robbins. Mrs May’s Government has relied upon various ad hoc subcommittees to deal with Brexit since Article 50 was triggered in March 2017. But since the controversial Chequers summit this summer the Prime Minister has held weekly off-the-books meetings with her core (i,e, Remain supporting,) advisers and civil servants present.

Of the secret gatherings, one source told the London Evening Standard: “In terms of democracy this feels like a scandal.”

Other members of May’s government are, like their boss, being caught out of lies they have told to try and hide the extent of their surrender to the EU on Brexit. Labour MP and ardent supporter Kate Hoey challened the Attorney General over comments made by the Secretary of State of Northern Ireland about the backstop arrangement if it is enforced after the implementation period. Conservative frontbencher Karen Bradley claimed last week legislation in Northern Ireland would remain in line with the UK if the Brexit backstop was implemented. Speaking in the House of Commons, Kate Hoey claimed the remarks from the Secretary of State for Northern Ireland were “not accurate”.

She said: “The Attorney General has been very honest I think in the downside of this backstop. That’s even without the legal advice, so we dread what would actually be in it if we did see it.

“Could I ask him about the Secretary of State for Northern Ireland, who on Sunday in the Inside Northern Ireland politics with Mark Devenport, actually said ‘even if the backstop kicks in Great Britain will stick to the same rules as Northern Ireland’.

“Would the Attorney General have a word with her because she is going around Northern Ireland on a tour and saying some things which are actually not accurate, and giving the people of Northern Ireland the very wrong impression about what this agreement means.”

Mr Cox replied: “The regulatory regime in Great Britain will be a matter entirely for the Government of the United Kingdom.”

This echoed the comments made by The Prime Minister when she was questioned on the issue. Unfortunately as has now been revealed the so called backstop would leave Northern Ireland operating under EU jurisdiction and the UK could not terminate the agreement without the consent of all 27 EU member states, a move that Ireland’s government in Dublin have promised they would always veto. This is perhaps the worst aspect of the sellout deal made in secret by Theresa May (it rhymes with betray,) with the EU.

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May hoping Unicorns Will Come Along And Save Her Government

Watch television news (BBC, ITV or Sky) or read the news online or in print and you might get the impression that Theresa May has seen off her critics in the Conservative Party and everything inthe political village and the country is hunky – dory as she heads off to Brussels to sign her sellout deal with the EU and bring to an end 1200 years of British sovereignty – or 1600 years if you count from when the Romans left rather than when we became nations rather than a bunch of squabbling tribes.

It is all fake news of course, well what else would you expect from mainstream media. The so – called Gang Of Five, the government ministers who want her to change the draft agreement with the EU have not given up, the DUP have not meekly fallen into line, the Labour Party have not accepted that being ruled by Brussels as an EU vassal state is the  best outcome. Labour, the DUP, and the Scottish National Socialists have some experienced political players in their ranks and they are waiting to see if the EU accepts the deal (current news is the Bastards of Brussels are now demanding even more concessions, with perfidious Gaul claiming access for their marine environment destroying factory fishing vessels to British territorial waters and Spain expecting May to cave in as she caved in to Dublin over the Irish border issue, and hand over Gibraltar.

And if Theresa the Appeaser does not give in again the EU will not sign the deal, and if she gives in again it can only strengthen the case of those aiming to bring her down. As things stand there is no chance of it getting through The House of Commons.

As her dream of thwarting Brexit flounders (she has always been a rabid remainer,) and moresenior members of her government threaten resignation if major changes to the agreement cooked up by UK civil servants and Brussels bureaucrats according to political sources,  Prime Minister May is reportedly going all in on what one lawmaker described as the “unicorn fantasy island” solution: Replacing the Irish backstop (perhaps the most contentious aspect of her 585-page draft agreement) with a commitment to find a “technological solution” that would avoid the return of a hard border between Northern Ireland and the Republic of Ireland, according to the Sun and the Financial Times.


Thersea May looking paranoid (picture: The Sun)

According to a Sky News report, the introduction of a commitment to find “technological solutions” might be enough to win over a few Brexiteer Tories by helping to assure them  that the UK would not find itself trapped in the customs union indefinitely following Brexit. However, serious doubts remain about whether the technology even exists to carry this out, the EU having illogically insisted that the solution currently used without difficulty on borders with norway and Switzerland wil not work for Ireland . May reportedly pledged to explore adding the technology clause during talks Monday night with Ian Duncan Smith, Lord Trimble, Lord Lilley and Owen Paterson. In theory, technology would allow the EU and UK to maintain a “soft border” in Northern Ireland even if the two sides fail to agree a trade deal.

May is scheduled to travel to Brussels on Wednesday to finalize the draft plan and also hammer out details of the accompanying political agreement (which is also facing some complications related to France and Spain, which are pushing additional demands (sic) over and above those included in the draft).

If she can’t secure a workable agreement and get it through parliament, it’s likely that a summit set for Sunday will be cancelled, and the European Union will begin contingency planning for a hard Brexit.

Theresa May Touts “Secret” Brexit Deal With EU – Instantly Blocked By DUP


Picture source: AFP / Getty

A report in the Sunday Times is accurate, May has assembled a detailed “secret” Brexit plan that, among other details, would kill off the controversial Northern Ireland “backstop” that had become the main obstacle to further negotiations.

Working in secret, May has reportedly developed a detailed, 50-page plan for a Brexit treaty that will allow the entire UK to remain within the EU customs union – that is, until a final deal can be hammered out during the transitionary period, which Brexiteers fear could mean “forever”.

As part of the new “secret” deal, May has effectively scrapped most of her controversial four-page “Chequers plan”, and replaced most provisions governing the single market and customs union with an agreement to hash out a “Future Economic Partnership” – essentially an open-ended agreement to continue negotiations that leaves open the possibility of reaching a free trade deal like the one enjoyed by Canada, a provision that is bound to appease at least some of the Brexiteers.

However, the Democratic Unionist Party (DUP) a Brexit-supporting Northern Irish party currently propping up Theresa May’s minority government has rejected concessions to the European Union (EU) which could have left Britisg citizens in the province subject to EU judges for years.

The Prime Minister had reportedly persuaded EU bosses to drop their insistence on splitting up the United Kingdom and separating Northern Ireland from the rest of Britain’s Home Nations with customs checks in a so-called “customs compromise”.

Northern Ireland’s Democratic Unionists Party (DUP) had threatened to vote down the budget if the UK was divided in this way. Mrs May proposed to keep the entire UK tied to the EU’s Customs Union as a compromise, while Brussels was pressing for Northern Ireland to be subject to Single Market regulations as well.

Throwing this “compromise” out, the DUP’s Westminster leader Nigel Dodds said: “If Northern Ireland is subject to EU Single Market regulations, then it will also be subject to the European Court of Justice in some form as the arbiter of those regulations.

“This position leaves Northern Ireland a rule taker from Brussels. We’re confident we can get a good deal, good for all four corners of the United Kingdom.”

May has been despoerately trying to keep Britain tied to the EU by stealth ever since the process began, though she never committed herself in the brexit campaign, (she’s always been the kind of politicians that in public goes the way the wind is blowing, has revealed by her actions she is privately a rabid remainer and a globalist.

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BA and Aer Lingus chief’s reply to shirt lifter Varadkar’s Brexit threat

The Irish turd – burglar Taoiseach (prime minister) Leo Varadkar last month threw a hissy fit because he was not getting his own way over Brexit and threatened that British planes may be unable to fly over Ireland in the event of a no-deal.

William Walsh, the CEO of International Airlines Group, which owns Aer Lingus and British Airways, responded to the warnings, adding that Brexit was “inevitable”. Guesting on BBC’s Radio 4 Today programme, Mr Walsh was asked about Varadkar’s threat. He replied: “It wasn’t from the Irish Government, it was a comment from the Irish Taoiseach in response to a question.

“I am not sure exactly what he meant but the idea that airspace will be closed for flights transiting a country, that is not going to happen, so I am not concerned.”

The Irish Taoiseach also sent the UK a fierce warning about the implication to aviation if there is not a deal secured between the UK and the . Mr Varadkar, said: “The situation at the moment is that the UK is part of the single European sky.

“If they leave the EU they are not, and that does mean if there was a no-deal hard Brexit next March, the planes would not fly and Britain would be an island in many ways.

OK, I know it’s Ireland, but how did this thick twat get to be anything higher than an office cleaner. Does he not know that access to airspace above a nation is governed by international treaties, it is not subject to Euronazi diktat.

David Davis struggles through interview with a sick bucket by his side.

Brexit Secretary David Davis, appearing on the Andrew Marr Show this morning requested a sick bucket be placed next to him in case he threw live on air. The Brexit Secretary, who was suffering from a stomach bug, then struggled through the interview which focused on progress made towards a transition deal for the UK’s leaving the EU.

Mr Davis was praised by the corporation’s editor of live programmes for his “commendable concern for our studio floor”. Rob Burley, who is the former editor the Sunday political programme, joked that while Mr Davis had “made it to the end” he doubted he would be “sticking around for breakfast”.

Persevering through the interview, Mr Davis insisted that the Government would find a solution to the Irish border, adding that this week’s breakthrough with Brussels made the likelihood of a trade deal “incredibly probable”.

He added that it would be the “most comprehensive one ever” and would make the prospect of a hard border in Northern Ireland much easier to resolve. Although some Bexit supporers (half of us Stirers included,) believe the concession given as part of the transition deal, to remain tied to the EU’s pernicious Common Fisheries Policy is a betrayal of our fishing industry, so long as control of fishing rights reverts to Britain at the end of transition it may be a price worth paying, with the die hard supporters of the Remain campaign, including Conservative, Labour, Liberal Deomcrat and Scottish Nazi Party MPs who have threatened to stop the UK leaving the EU, are now in reteat.

Almost 60 per cent of Brits now think the government should respect the referendum result and “get on” with delivering Brexit. In a new poll by BMG for Change Britain, respondents were asked if they agreed that “the government should get on with implementing the result of the referendum to take Britain out of the EU and in doing so take back control of our borders, laws, money and trade”.

A strong 57 per cent agreed and less than a quarter – just 22 per cent – disagree with the statement, according to the results, seen by the Guido Fawkes website. Twenty-one per cent did not answer the question.

In fact, according to the poll, support for implementing the referendum result and taking back control is backed in every age group, class, British region, and among supporters of all major political parties.

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Rebellion Against EU Authoritarianism Escalates As 8th Member Nation Threatens Referendum
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Irish Senator Says same Sex Marriage Vote Will Lead To Change Like Soviet Revolution

Irish gays celebrate with a new version of Riverdance called Alimentary Canal dance (image source)

The really annoying thing about news events like the “Yes” vote in Ireland’s same sex marriage referendum is that they always inspire lefties to start spounting the most inane drivel. Like this:

A pro-gay marriage Irish Senator David Norris (IND) has told journalists at Dublin Castle he hopes the vote to legalise same sex marriage will lead to change across the world, just as Ireland inspired the Bolshevik revolution of 1917 (WTF?). Senator Norris, was talking about how Ireland was a “small island on the edge of Europe” but that it could have a much wider impact.

The example he cited was the General Post Office (GPO) uprising in Dublin in Easter 1916. A group took over the GPO and fought against the British Army to maintain control of it for several days. The attack was unpopular at the time as it was seen to undermine the British and Irish efforts to win First World War.

Those responsible only caught the public imagination later when the British sentenced them to death, a ruling that proved hugely unpopular in what is now the Irish Republic. However Norris claimed their actions had “inspired” the Bolshevik uprising in Russia the following year. It led to the establishment of the Soviet Union and led to the deaths of tens of millions in forced labour camps and through famine.

He said: “We hope this vote will change things, in Africa and across the world just as the Irish rebellion of 1916 led to the 1917 revolution in Russia”. His comments were met with applause from the assembled crowd of pro-gay marriage supporters.

Change like the Soviet Revolution eh? Well let’s recall how that worked out. Stalinism, suppression of free speech, persecution of certain minorities including homosexuals, gypsies and Jews, genocide, food shortages, persecution of Communist Party members who questioned the leadership, shortages of food and clothing, economic and social stagnation, persecution of religious congregations, shortages of electricity, gas and coal, persecution of everybody, etc. etc. Well the Gay BLT and Yooman Rights lobby are certainly as authoritarian, self righteous and ideologically driven as the regimes of Lenin and Stalin. I have a horrible feeling this bloke might be onto something here.

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