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G7: Rich nations back deal to tax multinationals

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Re: G7: Rich nations back deal to tax multinationals

#171
post #27
post #7

Earlier quoted context omitted.

Because in practice if you make 1 million in a country, you’ll claim 1 million in expense in another country (with little to no taxes) for things like IP, trademark, etc.

Though whole accountancy process has many parallels to a pyramid selling, with the IP being the top of the pyramid located in some tax favourable country of the moment.

It's basically a form of hacking. Except not with computers but with the tax system.

Re: G7: Rich nations back deal to tax multinationals

#173
“The rules on making multinationals pay taxes where they operate - known as "pillar one" of the agreement - would apply to global companies with at least a 10% profit margin. Twenty percent of any profit above that would be reallocated and taxed in the countries where they operate, according to the G7 communiqué.”

How will taxing authorities determine which companies meet the 10% profit margin threshold? Which jurisdiction is this threshold calculated in for multinationals?

Re: G7: Rich nations back deal to tax multinationals

#174

I do wonder if we wouldn't be better off eliminating corporation tax entirely. The revenue of a corporation can, roughly, be: 1. Spent on goods or services from another company (including freelancers, contractors, etc.) 2. Spent on rent 3. Spent on capital purchases 4. Spent on wages 5. Spent on debt repayment or other forms of financing 6. Paid out in dividends 7. Spent on share buybacks 8. Invested in something els…

9. Just kept in a large pile like Apple does.

Re: G7: Rich nations back deal to tax multinationals

#175

I do wonder if we wouldn't be better off eliminating corporation tax entirely. The revenue of a corporation can, roughly, be: 1. Spent on goods or services from another company (including freelancers, contractors, etc.) 2. Spent on rent 3. Spent on capital purchases 4. Spent on wages 5. Spent on debt repayment or other forms of financing 6. Paid out in dividends 7. Spent on share buybacks 8. Invested in something els…

I think some people would find issue with the distribution of wages paid in #4.

Then again there are hefty (progressive) income taxes involved. The worse the distribution the higher the tax revenue.

Re: G7: Rich nations back deal to tax multinationals

#176
post #15

Earlier quoted context omitted.

It's complicated. "Money they made in their country" is hard to define. Large companies abuse intangible assets to shift profits around, but it's hard to say at what point abuse starts. For example, Google USA sells advertising to its clients. But, the assets it is selling are actually owned by Google Ireland. Google Ireland charges Google USA a license fee of 100% of the revenue they made. Suddenly, Google USA has n…

> Probably the best solution is a minimum tax worldwide. Wouldn't that make companies pay taxes in countries they are based in (as opposed to where they make money)? Anyway this could be the push that the EU needed to start their own Silicon Valley.

It removes the tax benefit of realizing profits abroad, which would likely bring revenue back to the market where it was earned.

I suppose a company could still move profit wherever they choose, but mostly likely inertia would keep it in place.

Re: G7: Rich nations back deal to tax multinationals

#177
post #158

I already said that the pandemic would force the entire world to lean to the left in terms of politics. It's inevitable. I'm very happy about that decision, but I'm not really confident it will lead to something. I'm also a bit cynic that it took a pandemic to make countries realize they need money. I'm also waiting to see if government are really planning to fight against tax havens. The problem is that it's impossi…

If the tax havens are democratic (and most are) then government boycotts + divestment + sanctions could go a long way.

Imagine being a panama citizen, your government is hellbent on protecting foreign billionaires from paying taxes in their home country. Now the Panama Canal is seeing only 50% of the traffic with resulting job-loss, the national team is no longer allowed to play in Copa America, and your countrymen have to play under a different flag if they go to the Olympics. And all because of a government policy you don’t agree with.

You will probably factor that in when you decide who you will vote for in the next election.

Re: G7: Rich nations back deal to tax multinationals

#178
As there are some misinformation and confusion, I try to summarize a few points: What is it: Pillar 1 tries to tax the digital economy (FAANG etc., scope still under heavy discussion). The goal is to prevent a digital tax in each country. Basically, the profit will be taxed in market states (i.e. Google pays tax in Germany). Pillar 2 tries to impose a global minimum tax rate. Countries levy a top-up tax on the foreign operations of their headquarter companies (i.e. difference between minimum global tax rate and effective tax rate) Who will be affected: This is different for Pillar 1 and Pillar 2 but both only want to tax multinational corporations defined for example by sales (> EUR 750 m turnover for pillar 2) and only if you have some minimum foreign operations. So your typical small company is not affected at all. What's so genius about this project: The OECD is very worried that there are still some loopholes, so they want to close them. They do it by basing the effective rate on IFRS income (or US GAAP) with some adjustments. IFRS income is also the basis they report to shareholders, so companies have a problem: Higher IFRS -> more taxes to pay How do the countries ensure that all countries participate: You don't have to impose a global minimu rate. If one country doesn't do it, other countries can levy the top-up tax through a different system (undertaxed payments rule for those who want to look it up). What's the position of the Biden Administration: The USA has their own system called GILTI which is accepted as well. It looks like the USA gets away again by participating but in the end, they will decide we won't follow the rules. Is this fair? Opinions differ. Why should highly developed economies like Ireland, Switzerland, Singapore not be able to set their own tax rates. They invest a lot in the education of their people. And if you think tax is fair, you don't know life. What countries will do is increase tax on profit but decrease other "taxes" (i.e. price on mining rights, social contributions etc.). If you have questions, AMA. I devote a large part of my life on this project.

Re: G7: Rich nations back deal to tax multinationals

#179

Earlier quoted context omitted.

I just wanted to show how silly is sounds that some ally countries think they can enforce actions on other countries

This happens all the time, see e.g.: https://en.wikipedia.org/wiki/Brussels_effect Of course you're free to ignore it, if you don't care about hundreds of million potential customers.

It links to the opposing effect too: https://en.wikipedia.org/wiki/Race_to_the_bottom

So it isn't that simple when it is something like this. So far history shows that tax havens work and the loop-holes are very challenging to close.

Re: G7: Rich nations back deal to tax multinationals

#180
post #15

Earlier quoted context omitted.

It's complicated. "Money they made in their country" is hard to define. Large companies abuse intangible assets to shift profits around, but it's hard to say at what point abuse starts. For example, Google USA sells advertising to its clients. But, the assets it is selling are actually owned by Google Ireland. Google Ireland charges Google USA a license fee of 100% of the revenue they made. Suddenly, Google USA has n…

> Probably the best solution is a minimum tax worldwide. Wouldn't that make companies pay taxes in countries they are based in (as opposed to where they make money)? Anyway this could be the push that the EU needed to start their own Silicon Valley.

Do you really think something like the SV can be created top-down?
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