As the Guardian reports this morning:
George Osborne, the chancellor, has joined forces with the German finance minister, Wolfgang Schäuble, to announce an international crackdown on tax avoidance by multinational companies.
Osborne said he and Schäuble, meeting at the G20 finance ministers' summit in Mexico, had called for "concerted international co-operation to strengthen international tax standards that at the minute may mean international companies can pay less tax than they would otherwise owe".
Osborne and Schäuble said they would back work by the Organisation for Economic Co-operation and Development to identify possible gaps in tax laws.
The joint statement by the two countries, a rare example of Anglo-German co-operation, admits, that "international tax standards have had difficulty keeping up with changes in global business practices, such as the development of e-commerce in commercial activities."
The two countries add: "As a result, some multi-national businesses are able to shift the taxation of their profits away from the jurisdictions where they are being generated, thus minimising their tax payments compared to smaller, less international companies."
This statement is, I have to say, true. It's something I and the Tax Justice Network have been arguing for a decade, so how could I disagree?
The trouble is that Osborne and Schäuble have got all their logic on how to address this issue wrong. What they are asking the OECD to do is tinker with its transfer pricing rules to stop this abuse. The problem for them is that it is those transfer pricing rules that make this abuse possible and no tinkering with them of any sort will prevent this abuse from being possible. This needs some explanation and as a result this blog may be a little long and wonkish: stick with it. At the end you should understand exactly what we're up against.
What we're talking about is how profit is allocated in multinational groups of companies. Let's create such a group. It has four members. Let's call them A, B, C and D. A makes shows in country A and B, C and D sell them in countries B, C and D. Simplistic, but entirely possible.
Now, transfer pricing rules assume when trying to set the prices at which A should sell to B, C and D that each of these companies is entirely independent of each other. They're not, of course. They're all under common ownership but we're asked to make believe they're not. And then transfer pricing rules look for what are called 'comparable' free market prices for the same shoe and that is the price which is used for the sale within the group.
Now let's suppose there is such a price and the result is that if it were used the comparable price basis would result in the companies each making £1,000. That is what the OECD seeks to do, and it then says the result is fair. There is, however, a problem. The group of companies actually makes £5,000.
There is good reason for the fact that it makes £5,000 and not as the comparable price basis would suggest £4,000. In fact, if it did not make more money as a group there would be no reason for the group to exist: there might as well be four independent companies because having the group would make no sense. The economic logic of all groups is that more money is made as a result of their being in existence than would other wise be the case.
How does that happen? Well, in this case the factory is more efficient because it has more guaranteed orders by having outlets in three countries. As a result there are bigger production runs and cost efficiencies But there's also a saving in design cost: one product suits three markets. Separate ones are not needed for each. And then each market gives more intimate feedback on changes needed so the rate of innovation is higher than in separate free standing companies that might not talk to each other And maybe an overall brand with increased awareness is created where the benefits can cross between companies. You get the gist: more profit is made as a result.
The question is where is that profit taxed?
Now, the UK did have what is called a residence based tax system. Suppose company B, here was in the UK and owned all the others. Under the corporation tax system we had from 1965 until the Tories came to power we had systems to eventually mean that all the profits af the group were taxed here in the UK. The three essential mechanisms to do that were first the transfer pricing rules, imperfect as they are. The second was controlled foreign company rules: if one of the trades was in a tax haven and too much profit was being allocated to it then under the controlled foreign company rules (and I simplify massively, but fairly) that tax haven subsidiary could be deemed to be in the UK for tax purposes (yes more make believe, I know - but international tax depends on it right now) and so be charged to UK tax rates. Last, dividends from each of the subsidiaries were taxed at UK tax rates when received in the UK with credit given for tax paid abroad.
Using the three mechanisms in then end all profits of UK multinationsl should in the end have been taxed here in the UK.
In 2009 Labour undermined this system, but not fatally. They removed the tax on dividends received from the foreign subsidiaries. They did it under pressure from big business. It was a mistake. But in theory transfer pricing and controlled foreign company rules should still have retained residence based worldwide taxation on UK based companies.
So Osborne went a step further and abolished the residence basis. He said he only wants to tax UK companies on their UK profits and none from abroad. So next year for all practical purposes the controlled foreign company rules go from UK tax (again, I simplify - but that's the stated aim). And dividend tax has already gone. And so we're just left with transfer pricing. Companies know that and are anticipating it. The law may not have quite changed yet, but the behaviour has, not least because many countries already use Osborne's preferred territorial basis for tax - only taxing profits arising in their states.
Now, let's go back to A,B, C and D. Each company under transfer pricing rules would make £4,000. But they actually make £5,000 between them. The incentive when there is territorial tax, no controlled foreign company rules and no tax on dividends coming back from subsidiaries is simple. The very strong incentive is to put the missing £1,000 in another company in a tax haven. That tax haven company charges for what it calls 'intellectual property' - that's the supposed foresight that comes from group buying efficiencies, group designs, shared marketing, and so on. And the tax haven subsidiary charges each of the other companies for this intellectual property to make sure they really do only make £1,000 each. That's done by transfer pricing of course.
It's either done by increasing the price of the show from A (which company will be in a country where the transfer pricing rules are very lax so that all the excess profit can be transferred on from that company to a tax haven - Ireland is a perfect example of a country with such lax rules) or each of B, C and D will pay a royalty on their sales to the tax haven fro the use of the marketing expertise supposedly sold to them by the tax haven entity (let's call it E).
Now E will make £1,000 either way. That's the missing profit.
Under transfer pricing rules that profit can go there. And if we had a residence basis of tax one day we'd get tax back on that in the UK, either by challenging the transfer price for its sales (very hard - there is no comparable as this intellectual property is only sold within the group) or by taxing its dividends to the parent company or by making it a controlled foreign company. But now the second and third options have gone. And transfer pricing only applies to sales into and out of the UK in this case - and not all the sales in the group are located that way. So in other words, its now utterly beyond the UK's control to challenge much of the shift of the profit into company E in a tax haven and probably beyond its control to tax it when it is there because transfer pricing rules don't give us that power - and George Osborne has now said he does not care what happens outside the UK.
The result is that the missing £1,000 - now dressed up and moved into a tax haven - will fall out of tax because transfer pricing rules assumes it cannot exist as it assumes there is no group to give rise to it whilst our new territorial tax rules stop us claiming it back even though it clearly does exist.
The result is the most massive incentive for large companies to move profits - and they're taking it. And George Osborne has helped make it much, much worse.
No tinkering with transfer pricing will now change this. The scene is set for this abuse - and Osborne even planned it. He actually forecasts that corporation tax alone will not see an increase in revenue over the next few years precisely because of this. In other words, he knows this will happen and designed it but is blaming the OECD for it.
We have to blame Osborne.
But we have to also say transfer pricing can't work because it assumes something that is not true - which is that there is no group when there is. It's illogical to do that. Only taxing groups now can work. That's unitary taxation. It is possible. But whilst countries refuse to consider it companies will walk all over us, as they are. But that's another blog.
PS apologies for typos and other errors - written at 5 in the morning before starting a long meeting - and to explain why Osborne is just wrong, in a hurry. I amy edit again later.
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Apologies, Richard, I am struggling a bit with the example so I wonder if you can help? If the Group makes an overall £5,000 profit as you suggest, let’s assume the external total costs to the group are £10,000 (£9,000 producing and £1,000 selling the shows) and the total revenue for the Group of selling them is £15,000 to its external customers. “A” makes the shows and sells them to “C” and “D” for a total of, say, £12,000 being the comparable independent transfer price for a produced but not marketed show. As governments are cooperating, this is the agreed transfer price for all countries for a produced show. So, the sales companies “C” and “D” would make a total profit of £2,000 (external revenue of £15,000 less transfer price of £12,000 from “A” and their own selling costs £1,000). This £2,000 will be taxed in countries “C” & “D” as it doesn’t matter where it customers are resident if they have no PE there. Now “A” surely makes a profits £3,000 (agreed transfer price of £12,000 to “C” & “D” less external production costs of £9,000), which will be split and taxed in the countries where the shows were produced in. So a total of £5,000 (£2,000 plus £3,000) has been taxed in the various countries, so where is the drop out or am I missing something?
You’ve made up a different example so you get a different answer – as you’re ignoring that there is no obligation on governments to agree 100% of profits are taxed under transfer pricing rules since TP can virtually ignore accounts – but does so in a way I show that virtually guarantees less than 100% is taxed – which MNCs can move at choice or even exploit
The error is your assumption of cooperation and 100% taxed
I’m also struggling with certain elements of this.
I know a little bit about US tax (not a huge amount), and US companies are generally taxable on a worldwide basis. They get credit for foreign taxes paid, but they also get the opportunity under their tax systems to legitimately defer US tax by accumulating foreign profits overseas, and then reinvesting them. They don’t actually pay tax in the US on those profits until they are repatriated.
So assume a US multinational does a Google or a Starbucks, by using Ireland or Luxembourg, and it pays a small amount of foreign taxes but doesn’t remit the profits back to the US, is it not building up a deferred tax liability in the US which simply doesn’t show as such, because (a) there is no obligation to repatriate it, and (b) so there is no ability to calculate the amount of US tax which might be paid eventually.
However, if the US multinational was not using Ireland or Luxembourg or other low-tax countries, and so was paying much more tax in (say) the UK, then the UK would collect more tax, but the US would permanently lose out because when the profits are repatriated to the US, by the time that the US has allowed the foreign tax credit against the US tax liability in respect of the UK tax already paid on those profits, there is nothing further to pay (or a negligible amount, depending on which state the US company is based in).
It is obvious that the UK would be getting tax which is (a) currently going in much smaller amounts to Ireland or Luxembourg, and (b) which is ultimately otherwise POTENTIALLY destined for the IRS, but surely the IRS is not going to be keen on losing out on what it would POTENTIALLY get if those profits were distributed?
Therefore, there appears to be a clear conflict between a global corporate tax system in which some countries tax on a residency basis, and in which other countries wish to tax on a territorial system. Double tax treaties prevent taxation of the same profits twice, and/or unilateral tax relief helps when there is no double tax treaty in place between the affected countries, but there will clearly always be tax rate arbitrage between various countries.
US multinationals are not necessarily avoiding tax by using low-tax jurisdictions, because they will be liable to pay full US taxes (less credit for foreign taxes paid) when those profits are repatriated. Surely it is logical that they will accumulate those foreign profits in a low-tax environment pending reinvestment and global expansion, as to pay unnecessary tax (exactly as per their tax code) on an annual basis, which leaves less for reinvestment, and may require them to borrow more capital to fund overseas activities, cannot be in the best interests of the company or its shareholders.
Note that this is pure tax deferral, not avoidance, and is exactly as provided for by the IRS. If the US wants to collect more tax, then all they have to do is tax US companies on overseas profits whether they repatriate them or not, but again the foreign tax credit system will impact materially either on how much the US collects, or alternatively how much has been already taken by the foreign country.
Unless there is global tax harmonisation, surely this problem is unsolveable?
Unitary tax solves tuis problem
The US is an exception by the way – it’s remittance basis is I think unique
But the UK does not need IRS consent to tax corporations on their profits really arising in the UK – and ypu seem to assume they do
Why?
As for the assumption US corporations will pay tax on their offshore profits – that is clearly not going to happen
Why assume it will?
Your basis for argument has no relationship to reality
Richard
The US may well be an exception, but its still the world’s biggest economy and in recent weeks it has been the tax affairs of major US multinationals which has been under the microscope.
I agree with you – the UK does not need the US’s permission, but it sure isn’t going to sit back and let the UK grab a share of the profits of the US multinational which the US ultimately hopes to tax. How long do you think that scenario would last?
I also agree with you – it is impossible to predict when a US corporate will pay tax on its offshore (let’s call them “foreign”) profits, but nevertheless that’s what their tax code provides for. I think what you are saying is “well if you can’t be bothered to collect the tax on profits generated from the UK by your companies then we in the UK will grab it instead”. Correct?
But what happens if/when the US changes its tax policy and wants its share of that tax? We then end up with an almighty row over residency-based tax versus source-based tax. What effect does that have on every single OECD-model double tax treaty in place? I suspect the ultimate answer, after years of haggling, is that the UK would not collect any more tax from the US multinationals, and the US will collect a lot more than it does today.
Ah, we live in a world where our tax sovereignty is subject to US consent
I don’t think you’ll find agreement on that one
But presumably company E would have undertaken valuable economic activity establishing (or buying) and then maintaining the IP in order to justify and sustain charges to the other companies. If it has then it should get paid for it whatever the tax rate. If it was actually Ireland shouldn’t it be encouraged to tighten up on its TP rules through cooperation. So the problem you identify is a result of the TP rules not the other points.
Buying IP is ignored in unitary tax
Having staff maintain it allocates a formula apportionment
It will be low though
And that’s right – people and sales create that value, not an artificial factor of production
While under transfer pricing, the UK doesn’t need the IRS’s consent, surely for unitary tax to work, the UK does need the IRS’s cooperation. And as Ralph says, if they are going to be net losers, what incentive do they have to co-operate.
As for US companies tax on offshore unremitted profits, they are vainly hoping for a change in the law to let them remit that at a lower tax rate, but investors are already starting to adjust those balances for tax when valuing the US companies.
I don’t think so
The EU is proposing unitary – and I think will have it within 5 years or less
The US can take it or leave it
We’ll claim the profit whether they like it or not
“The US can take it or leave it”. Really? I don’t think the UK would win that one.
There must be a less than 30% chance of the UK still even being in the EU in 5 years time. Cameron is going to have to hold a referendum and at the moment there is not a cat’s chance in hell of the UK population voting to stay in.
Expulsion is more likely given the current mood in Brussels and Berlin
Sorry I thought your blog entry was on why cooperation between governments to agree mutually respected transfer prices will not work.
It doesn’t for the reasons I note – there is no requirement that governments agree
And it’s also that TP can deliberately result in the abuse by corporations I note by exploiting that
As an accountant, you know that even when all operations are in one country profits are pretty fungible, you can arrange to declare pretty much what suits you when it suits you; I know that this is a bit of an exaggeration but not a very big one. Why not simply give up the attempt and tax turnover, obviously at a much lower rate than profits to get pretty much the same result? One of the reasons that transfer pricing can be cooked so easily is that the profit is a relatively small difference between the much larger numbers of costs and sales revenue. Even if there was a little bit of “adjustment” its effect of the total revenue could not be very great without being obvious even to HMRC.
That’s called VAT
It is not a tax on companies
It is a tax on the poor consumer
Not necessarily. Think of it as the equivalent of employers NI so a cost to the company and not the consumer. Companies wouldn’t be allowed to set input off against output.
You ignore tax incidence
Employe’s NIC is paid by staff and not companies in th form of reduced recorded gross pay, for example
Sorry – it’s economics that matters here
It has been a while since I commented but what has become very clear in the past few months is that you really do not know much about tax. From the comparison of dividends or salary, to your understanding of TP, if your lack of understanding was not so worrying it would be simply amusing.
Forlornehope suggests a possible solution (bizarre but possible) you identify it as VAT. VAT is only one possible way of taxing “turnover”.
As for your views on TP expressed above, just keep providing your examples and digging your hole ever deeper.
Very odd then how a director of HMRC and former senior partner at PWC made very clear just how technically correct my analysis was tonight
I know who I am inclined to believe
It strikes me that paying no UK tax puts say Starbucks at a competitive advantage against my local coffee shop that pays full whack on its profits. Surely that is the real point that conservatives should be concerned with. Big global businesses can flourish and invest, while local taxes and bankers who won’t lend and when they do, mis-sell dodgey “structured products”, screw my local coffee shop to the floor.
Osborne is definitely not a friend of sme’s despite his posturing otherwise. Can’t we redress the balance in a more targeted way. Increase the VAT threshold to take business with turnover under £ 1 million out of VAT. While we’re at it, extend VAT to all financial services and media apart from childrens books. Also put up employers NIC on large business or scrap it for small businesses. Let our smaller local businesses take up the job creation initiative. Small is beautiful.
You are 100% right
100% right
I’m obviously being stupid here but I value your insight! If you are worried that companies are avoiding paying tax on their profits you could assume that they are making the average profit on sales for a company in their sector and charge them tax on that “profit”. That’s a bit brutal but should catch the likes of Starbucks. Mathematically all that you have done is to levy a tax on their turnover. BTW, I do recognise that this is pretty much the same as VAT but don’t see how the effect of this is actually any different from taxing profit.
I believe in tax on capacity to pay – not poll taxes
And I also believe in taxing capital – the tax you propose does tax turnover and that impacts on the poorest by affecting prices. Taxes on capital impact wealth
The question is, who finally decides how much tax is liable and might be paid? Douglas Carswell, who, I suspect, you might not agree with wrote a book “The End Of Politics” to describe the attrition on government. One blogger, The Slog, asserts we are really talking about the end of sovereignty. If the multinationals decide themselves what they might pay, how and why then a nation is no longer “tax sovereign”. If that is the case, what happens next? In France in 1789 they found an effective way of dealing with their leading tax avoiders at the time.
I have no doubt many of the wealthy have only contempt for the state – and MNCs too
It is our job to assert it
Richard, if you didn’t see the PAC hearing, yesterday, you should take a look at the central passages on Starbucks etc. [still streaming on BBC democracy live].
Committee members are starting to ask the right questions, and with confidence
-about Revenue staffing
-about willingness to contest questionable pricing
-about [most interestingly] the whole OECD model set-up. Lin Homer got no sympathy for her suggestion that public incomprehension of the Starbuck’s etc issue was down to the complexity of the issues.
Committee is returning to the subject, shortly.
Hi
Next hearing is next Monday
Sometimes committees take advice on what to ask
Richard
“I have no doubt many of the wealthy have only contempt for the state — and MNCs too”
Though that is hardly surprising, given how easily our representatives are to buy.
But then, a lot of people show little regard for the state given that they think the “state” is politics and politicians.
They need reminding that the state is THEM, the politicians our servants (and so do the politicians)
[…] One might say, how times have changed. The idea that the ICAEW would have wanted debate on these issues only five years ago would have been virtually unthinkable. So I welcome the process, and took part in last night’s debate. If invited I might go to others too. And for the record, I did not, as some expected, use the occasion to discuss my points of difference with David Gauke, who was there, since I thought them too well known (although the tax gap, country-by-country reporting, the General Anti-Tax Avoidance Principle Bill and others all got brief mention. I did instead, in the spirit of the meeting, which was looking at a new era in thinking, discuss the crisis facing corporation tax I wrote about yesterday. […]
I do not pretend to understand half of this.
However, I have just tried to get an epetition on the govt. website to ask the govt. to ban companies involved in tax dodging from being eligible for NHS contracts.
It was rejected, presumably on the grounds that some of the information would be confidential. It isn’t. Most of it is on the Green Benches website.
This wording is going through the Scottish Parliament at the moment, which is where I got the idea from.
Good idea….
Richard
Richard your suggested solution is ‘unitary taxation’ but do you believe that is likley to happejn any time soon ? If not do you have another solution while we wait for ‘unitary taxation’ ?
Others have suggested tacing sales rather than profits but you don’t seem keen on that.
Unitary tax could be in in five years of the UK cooperated with the EU
That’s a very fast pace of change on such things…
You are confusing Unitary Taxation with the EU proposed CCTB. They are totally different things.
CCTB looks to obtaining a consolidated EU tax base whereas Unitary Taxation by formulary apportionment is seen by some as a substitute for the arms length principle applying to related party transactions.
Needless to say, the EU supports the OECD arms length principle with regard to connected party transfer pricing, so the chances of having unitary taxation in 5 years is fanciful to say the least, particularly as the OECD rejected unitary taxation in 2010 and the UN Tax Committee of Experts have done likewise in 2012.
As for CCTB, the project has been going since 2001 and seems to be heading nowhere fast.
Wishful thinking on your part – and as usual utterly wrong on interpretation and much in fact
And of course you cannot prove me wrong or even try to.
The real fact is that you simply do not know the difference between Unitary Taxation and CCTB – which also means you do not fully understand transfer pricing.
“The Common Consolidated Corporate Tax Base is a single set of rules that companies operating within the EU could use to calculate their taxable profits. In other words, a company or qualifying group of companies would have to comply with just one EU system for computing its taxable income, rather than different rules in each Member State in which they operate.
In addition, under the CCCTB, groups using the CCCTB would be able to file a single consolidated tax return for the whole of their activity in the EU. The consolidated taxable profits of the group would be shared out to the individual companies by a simple formula so that each Member State can then tax the profits of the companies in its State at the tax rate that they – each Member State – chooses, (just like today.)” from the EU Customs and Tax web page.
This doesn’t look like unitary tax to me.
The you don’t understand unitary tax
Richard-
Perhaps I’m missing something in your example, but why wouldn’t the tax authority in Country “A” audit this group and make an adjustment to taxable income of £1,000? There’s very little economic substance in “E”, and an experienced tax auditor should be able to figure that out by taking a look at where this company is earning profits by comparison to how the business operates. Country “A” should earn the residual profit (or incur losses) in this business, and even if E does some “marketing” it’s certainly not why the business sells tickets. In this example, E would get its locally incurred costs reimbursed plus a small profit.
“That tax haven company charges for what it calls ‘intellectual property’ — that’s the supposed foresight that comes from group buying efficiencies, group designs, shared marketing, and so on.”
– A company can argue they have foresight, etc. in a tax haven, but that’s a risk to revenue much like falsifying what a company reports in its tax returns. An educated auditor should be able to figure that out – and the risk of adjustments/penalties/prolonged litigation needs to be high enough to discourage the use of tax havens without economic substance.
The adjustment is not made because legal form for IPR has won precedence in this debate and the fiction that value attributes to it is therefore maintained
Unitary tax beats that
I see that being abused in the cost-sharing area and other complicated structures where the tax haven country is the selling entity, for example.
That being said I don’t believe that legal form has always won precedence in this debate. Tax authorities rarely take a good hard look at the economic substance in many of these structures under audit. There also haven’t been enough jurisprudence in this area so tax authorities can rely on court decisions to disregard the structures.
If I understand unitary tax correctly, profits are assigned to each tax jurisdiction by reference to allocation keys – personnel, sales and assets for example. Unitary tax is going to have some similar problems because multinationals can inflate or minimize the number of people or assets in a certain location in order to justify higher profits in tax havens. I struggle to see how many countries are going to be able to audit a unitary system when it would be just as easy, if not easier, to misreport payroll and asset figures to tax authorities on a global basis.
I find some of your opening comments contradictory – sorry!
Re game playing – yes that is a risk, and I can easily think of some (appoint an ‘orphan’ sales agent i n a tax haven to have all sales recorded there, for example). Strong anti-avoidance measures will still be needed: we can’t trust these people.
Won’t the transition to a unitary tax system be a get rich quick scheme for the Big 4 accountants that will make tax avoidance fees look like small change?
That is a risk
One we may have to take
Richard– I don’t understand what’s contradictory? In your example, the shows are developed in Country A. Country E has done nothing special and has no economic substance to earn the £1,000. Certainly companies are incentivized high priced tax firms to come up with cost-sharing systems where the tax haven participates in the funding of the “future IP” and/or do “valuations” of IP to sell to tax havens. That being said, I don’t see how these structures have economic substance – that’s the anti-avoidance question. The tax haven isn’t developing the shows – the main reason why the multinational was formed in the first place. Consequently,an auditor should include that there should be very little income in the tax haven.
It appears that the unitary system comes down to valuation of assets, reports of how many people work in each entity and reports of sales in various tax jurisdictions. In the U.S. there are plenty of tax consultants who come up with complex structures on the state level as well, including unitary states, – and that’s in a situation where the personnel, assets and sales data across states are on an apples-to-apples basis – same payroll reporting requirements and the same accounting standards. We certainly don’t have the same situation across countries – which would be a huge tax arbitrage opportunity for multinationals. How is this beating the OECD system?
It seems that under a unitary system multinationals will be incentivized to hire tax consultants to write-down the value of intangibles or other assets in high-tax countries (plus fire people in higher-tax countries) and do the opposite in low-tax countries. The valuation/write-down of assets alone would be another extraordinary money making business for tax specialists in a unitary system as well.
I really do think it naive of you to believe it now beyond our wit to design purposive anti-avoidance principles (completely consistent with EU law ) to deal with this
an auditor should conclude – not include
(a) I believe you are proposing this method on a worldwide basis – are you not?
(b) Since it’s not just an EU issue, it’s naive to ignore potential pitfalls in developing anti-avoidance principles on a global basis. What may work in the EU may be a non-starter elsewhere.
(c) I still don’t see why my comments above were contradictory?
Ideally this is worldwide
But it can start from one country if it wishes – EU is better
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