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Google's Paris HQ raided in tax probe

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Re: Google's Paris HQ raided in tax probe

#231

Earlier quoted context omitted.

Solution: Get rid of tax law as one of the major sub-industries of the legal profession. When I no longer need a lawyer to submit my taxes, I'll start caring about corporate tax loopholes.

Addendum: make filing taxes a largely automated task where data are shared with the government so the online submission is merely a review of what is already on your W-4 (or what have you). Make it so dead simple it should take no more than 15 minutes for the average citizen with a computer. Anything that is purchased or paid to you should already be built in: if you paid mortgage interest, the deduction is automatic…

You can't make it "dead simple" when some of the concepts are not "dead simple." Let me give you the example of debt vs equity. Just because the company/lender codes it as such, does not make it so. What might be treated as interest deductions may ought to be treated as dividends instead. It may be difficult to make this entirely automated.

Re: Google's Paris HQ raided in tax probe

#232
post #20
post #4

"Several have been accused of using legal methods to minimise their tax bills." Since when is it illegal to follow the law? Sure, we all have different opinions on the legal gray areas and of whether certain or all laws are legitimate and to what extent - but come on, that quote is just ridiculous.

Don't know about American law, but in French the notion exists and is called "abus de droit"; just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation. For example, as an Irish company, you can open a subsidiary in France to do business in France. That's a right. But if you're doing business in France essentially, you can't make the French com…

Intent is a huge concept in english law too. As an example, 'good samaritan laws' are an incredibly new concept in the UK (eg, the last 12 months). It was eventually enacted not because it's ever been needed - it has never, not once, been needed - but so that people don't have to hesitate to act.

Honest intent may defend an action which would otherwise be illegal. Or you can skirt the edges with malintent and be found for it. Carrying a knife may be legal with demonstrable reason. Carrying a screwdriver may be illegal with malintent. And we trust the courts to spot the difference. And in general, they do.

America, however, has been raised on "a healthy distrust of government". They simply don't trust, or don't want to trust the courts to straddle such grey lines. They want nice solid black & white line so they can point to the law instead of the courts - and they want to see "the people" (juries) police the gray lines.

Personally, I think there's merits to both systems. But it's clear to see that both are very culturally ingrained. I think it's actually very difficult for either side to see the other clearly.

Re: Google's Paris HQ raided in tax probe

#233
post #20

Earlier quoted context omitted.

Don't know about American law, but in French the notion exists and is called "abus de droit"; just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation. For example, as an Irish company, you can open a subsidiary in France to do business in France. That's a right. But if you're doing business in France essentially, you can't make the French com…

For example, as an Irish company, you can open a subsidiary in France to do business in France. The whole point of the EU single market is that you do not have to do that. You can set up shop in Ireland and sell to the French market until the cows come home. You only owe Irish taxes (modulo the recent completely crazy VAT changes). Laws that say "forget the law, anything we think is unreasonable is illegal" are a gro…

Unlike the US, countries in the EU do not appear to be able to compete by offering favorable conditions to corporations and this especially concerns taxes.

which is a big design fault that hampers the EU especially as nations facing debt problems will use it to shore their finances up which keeps up and coming countries from doing that, being up and coming.

Re: Google's Paris HQ raided in tax probe

#234

Earlier quoted context omitted.

Have you worked in a software company like Google (Microsoft, Facebook, Amazon... ) ? I have. I'd be surprised if any software company of that size gave up even a single qualified engineer to avoid legal trouble (legal trouble that is entirely Google's fault and not the engineer's.) That's just not the way the market works right now.

These days i'm an engineering director at Google, so, yeah, i have :) I also worked at RedHat, IBM, and Microsoft, all of which would qualify. I actually don't know if Google has closed offices to avoid legal trouble. But definitely, other large companies i've worked at have, in the past, decided it's not worth the hassle to have those offices when the government started pressing interesting claims (i'll just use tha…

> I actually don't know if Google has closed offices to avoid legal trouble.

Google Beijing?

Re: Google's Paris HQ raided in tax probe

#235
post #79
post #49

Earlier quoted context omitted.

It's completely within the right of Ireland and Irish citizens to promote investment by lowering the tax rates, as it is within the right of France and French citizens to tax companies that earn profits in France according to French tax law. I really don't see a problem.

And yet Ireland has harsh austerity that has pushed many into poverty, so it wouldn't seem to be making much difference to citizens. http://www.irishexaminer.com/viewpoints/analysis/irelands-au...

I honestly think the two aren't linked. At least not as cause and effect, at least. Multinational investment drove the growth, but it was property madness that drove the bubble. So when the global economy faltered, there was a downturn in foreign investment - but it was the property bubble that burst.

I can still say that almost everyone I know here works for a multinational. So while they seem to artificially expand GDP (a huge amount of our GDP isn't actually domestic, and doesn't benefit us the same way domestic product would) - for us little folk on the ground, they still mean a lot, lot more jobs than we'd have otherwise.

How we actually domesticate this investment so it's not at risk of just flitting off to the next cheap destination, I have no idea. But I think that's the real long-term risk & challenge, not the stupid amounts of imaginary money people had pinned on the property bubble.

Re: Google's Paris HQ raided in tax probe

#236
post #20
post #4

"Several have been accused of using legal methods to minimise their tax bills." Since when is it illegal to follow the law? Sure, we all have different opinions on the legal gray areas and of whether certain or all laws are legitimate and to what extent - but come on, that quote is just ridiculous.

Don't know about American law, but in French the notion exists and is called "abus de droit"; just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation. For example, as an Irish company, you can open a subsidiary in France to do business in France. That's a right. But if you're doing business in France essentially, you can't make the French com…

[deleted]

Re: Google's Paris HQ raided in tax probe

#237
post #10

Earlier quoted context omitted.

" multinationals are allowed to take the resources of the various nation states they operate in while contributing nothing themselves". I agree with the sentiment that they should receive equal treatment than local/smaller companies, but saying that they contribute "nothing" is unfair and ingenuous, they do in terms of creation of local jobs and the direct and indirect taxes they pay for them.

Please not the trickle down theory again.

https://en.wikipedia.org/wiki/Trickle-down_economics means something different. "Creating jobs" is not "trickle-down economics".

Re: Google's Paris HQ raided in tax probe

#238

Earlier quoted context omitted.

Who says they don't have activities in Ireland? A lot of Google's employees are actually based in Ireland. > Just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation. Most countries have laws that say you can't do something JUST for tax purposes. You can, however, structure things in a tax friendly way, if there's a commercial motive to do so.

http://www.independent.ie/business/technology/google-hits-50... Over 5k employees apparently.

For comparison, the numbers I've seen for the Paris office are 2-300. It's a satellite office, not a headquarters.

Re: Google's Paris HQ raided in tax probe

#239

Earlier quoted context omitted.

Please not the trickle down theory again.

https://en.wikipedia.org/wiki/Trickle-down_economics means something different. "Creating jobs" is not "trickle-down economics".

There is nothing in your wikipedia article which says that "Creating jobs" is an antipattern for "trickle-down" economics.

Re: Google's Paris HQ raided in tax probe

#240
post #20

Earlier quoted context omitted.

Don't know about American law, but in French the notion exists and is called "abus de droit"; just because you can do something "in general", you can't do it with the specific purpose of circumventing another legal obligation. For example, as an Irish company, you can open a subsidiary in France to do business in France. That's a right. But if you're doing business in France essentially, you can't make the French com…

Honestly, I think "abus de droit" is a very interesting concept. I'm partial to liking it but I'm curious what the downsides are. Sure, some will say that it creates too much of a gray area, but that's life. Sorry. I think there's a lot more "effective" ambiguity when everyone is trying to dodge the spirit of the law and exploit loopholes. It creates chaos that lobbyists, consultants, and others can exploit. Focusing…

This is not just a problem with tax law, but any law. The problem with the spirit of the law is that it means different things to different people. Both intent (and morality!) differs greatly between various people. Hence we stick to the letter of the law. A simple example:

- Let's say one can do A, B, C and D. They all represent similar situations.

- For some reason, the government wants to block the above.

- They create a new law, blocking A, B and C. They forgot D.

Now, they might have wanted to block D as well. But how do you know? What if D gives you a significant advantage over competitors?

One thing I've noticed, hanging out with lawyers, is that governments often make a lot of half assed laws. Closing the "loopholes" isn't hard - it just takes time + requires proper work. Also, don't forget, some loopholes are there by design.

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