Paradise Papers (& Panama Papers)
Comments
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Pinno wrote:UK shell companies linked to £80bn money laundering:
https://www.ft.com/content/11d83f24-c49 ... 86f39ef675
Paradise papers shake Britains off shore tax havens:
https://www.ft.com/content/38e99534-c48 ... 86f39ef675
Netherlands to investigate 4,000 corporate tax deals:
https://www.ft.com/content/df1156dc-c49 ... 86f39ef675
Apple:
https://www.ft.com/content/3327c766-c32 ... 2b2cb39656"I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
Stevo 666 wrote:You're making the case for the prosecution against the IOM, as it were - you gather and present your evidence to support your case, not ask the defence to go and look it up for you
I'm afraid I don't have that info to hand, so off you trot to find it. Otherwise you haven't got much of a case, have you?
I thought you were playing the role of an expert witness, not the defence counsel.0 -
KingstonGraham wrote:Stevo 666 wrote:You're making the case for the prosecution against the IOM, as it were - you gather and present your evidence to support your case, not ask the defence to go and look it up for you
I'm afraid I don't have that info to hand, so off you trot to find it. Otherwise you haven't got much of a case, have you?
I thought you were playing the role of an expert witness, not the defence counsel.
The floor is all yours, my not so learned friend"I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
Objection.0
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KingstonGraham wrote:Objection.
To which part?
If you two are prosecuting/defending Counsel, can I be the Judge? A bit like Judge Judy but with better legs and generally more tired.Postby team47b » Sun Jun 28, 2015 11:53 am
De Sisti wrote:
This is one of the silliest threads I've come across.
Recognition at last Matthew, well done!, a justified honoursmithy21 wrote:
He's right you know.0 -
Or Judge Dredd.
I am law.Postby team47b » Sun Jun 28, 2015 11:53 am
De Sisti wrote:
This is one of the silliest threads I've come across.
Recognition at last Matthew, well done!, a justified honoursmithy21 wrote:
He's right you know.0 -
Matthewfalle wrote:KingstonGraham wrote:Objection.
To which part?
If you two are prosecuting/defending Counsel, can I be the Judge? A bit like Judge Judy but with better legs and generally more tired.
Like Judge Rinder then.0 -
Stevo 666 wrote:Pinno wrote:UK shell companies linked to £80bn money laundering:
https://www.ft.com/content/11d83f24-c49 ... 86f39ef675
Paradise papers shake Britains off shore tax havens:
https://www.ft.com/content/38e99534-c48 ... 86f39ef675
Netherlands to investigate 4,000 corporate tax deals:
https://www.ft.com/content/df1156dc-c49 ... 86f39ef675
Apple:
https://www.ft.com/content/3327c766-c32 ... 2b2cb39656
You mean you are too tight to subscribe for £1 for one month? Do you want me to lend you it? I have flexible terms of interest payment: Simple, amortized, fixed or compound.
Okay, so you have answered my questions (sort of) but do you think that the evasion is so nominal it shouldn't be pursued? We've endured austerity and from the point of the average man in the street or at least, the average small business who pay their way, what do you think they think of large corporations using holding companies in places like the IOM to reduce their tax burden (legally or otherwise)?
Do you assist corporations in setting up holding companies to reduce their tax burden?seanoconn - gruagach craic!0 -
Yeah. That sound cool.
Order in court, see. Who's trial is this case?
I reckon I'll be well cool at it.Postby team47b » Sun Jun 28, 2015 11:53 am
De Sisti wrote:
This is one of the silliest threads I've come across.
Recognition at last Matthew, well done!, a justified honoursmithy21 wrote:
He's right you know.0 -
Stevo 666 wrote:KingstonGraham wrote:Stevo 666 wrote:mamba80 wrote:Stevo 666 wrote:mamba80 wrote:No it fcuking well isnt and you know it. utterly simplistic,you yourself have said that banks wont move many workers as London offers soooo much more.. schools, culture, history, dining, 5% tax or close a few loop holes wont make londons millionaires suddenly move to Frankfurt... brexit might though!
You have to be self employed to be vat registered and have a decent turn-over, not open to the vast majority who r on PAYE regardless, when my mate tried to get his KTM450 as a business purchase as he used it to travel about the lanes to price jobs, he was told no chance as a enduro bike is clearly a leisure purchase! just like a jet!
many poorer people dont get back a cent in working benefits as they dont have kids or pay rent.
So you re found out and then standard retort..... come on it s getting boring.
Are you denying that for the vast majority on PAYE claiming back VAT is nt an option? or that to be VAT registered your vat taxable turn over is 85k in any 12month period...... or that living at home and having no children means no working benefits......
Your early post (posts?) were the one free of facts or evidence.
You stated that it needs to be one set of rules for all. There is.
Anyone can set up a small business and register for VAT. The only difference there is facts and circumstances, not rules. Like anyone in business, Hamilton can reclaim VAT on business purchases, the only difference is that he has made a high value purchase. Principle is the same. The only real question is whether his declared % business/private use split is reasonable.
There are a few million UK VAT registrations and anyone can register voluntarily regardless of turnover. Although as mentioned above, LH has not avoided any UK VAT
Unless he has, because his "business" in the IOM wasn't "in business". And that company didn't declare his business/personal use correctly when importing it to the UK.
Or am I wrong? I'm sure it will get investigated now, anyway.
IOM runs its own tax affairs and is responsible for gathering its own revenues (tax) and its own spending. If LH has avoided anything, it is to the detriment of the IOM. The impact on the UK exchequer is nil. Also he didn't import it into the UK (and fyi he isn't UK resident himself).
That aside, what was his declared personal/private split declared compared to the actual?
If he has done something wrong, it's up to the IOM tax authority to investigate. Although they signed off on the transaction in the first place.
There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK.0 -
TheBigBean wrote:There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK."I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0
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Stevo 666 wrote:TheBigBean wrote:There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK.
Is there a perception that IOM is less likely to investigate whether his business was "in business"? Otherwise, why bother with an IOM business at all, just import it directly to the UK, because the VAT rules are the same.0 -
Stevo 666 wrote:TheBigBean wrote:There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK.
https://www.gov.im/categories/tax-vat-a ... e-sharing/The Customs and Excise Agreement between the United Kingdom and the Isle of Man has been in place since 1979, when it replaced the previous Common Purse arrangements. Under the Agreement the Island keeps its indirect tax regime largely in line with that of the UK, allowing the free movement of goods between the 2 countries.
Amongst other things the Customs and Excise Agreement removes the need for customs barriers between the Isle of Man, the UK and the EU, and makes the Island part of the European VAT territory.
The Agreement also makes provision for the Revenue Sharing Arrangement (RSA), the agreed formula by which VAT and most other indirect tax revenues are split between the United Kingdom and the Isle of Man.0 -
Pinno wrote:Okay, so you have answered my questions (sort of) but do you think that the evasion is so nominal it shouldn't be pursued? We've endured austerity and from the point of the average man in the street or at least, the average small business who pay their way, what do you think they think of large corporations using holding companies in places like the IOM to reduce their tax burden (legally or otherwise)?
Do you assist corporations in setting up holding companies to reduce their tax burden?
As mentioned I cannot put an exact number on it but as the HMRC report shows, there are bigger issues out there in the tax sphere and the level of anti-avoidance etc is really pretty stringent now, despite the popular perception voiced by some on here. I can tell you that confidently because of the amount of time my team has to spend complying with all of this stuff, not just here but all over the world.
Look at what has been seen so far in the recent disclosures - the majority concerns high net worth individuals, not corporations. Many of them not even UK resident so it is more often than not the taxes of another country they are trying to reduce, not UK tax.
The other point is that a lot of what is being disclosed is from a long time ago - the Paradise papers cover 50 years IIRC? A lot of what was done that long ago may well have been perfectly legal and acceptable then because most of the rules we have now did not exist then.
Regarding large corporates or anyone else, as I've said before:-
- If they have a supportable filing position then there is no question, its fine.
- If they have taken a position on a tax issue, disclosed it and the tax authority disagrees then generally there will be arguments etc. Depending on who is 'right' - often on balance in complex/judgmental situations - there may be tax adjustments with potentially penalties and interest depending to what degree the position was genuinely supportable etc. That's the way it goes in the 'middle ground'.
- If they are doing it illegally (e.g. concealment of income etc) then throw the book at them. And the book is quite heavy when it comes to evasion. Simple really.
The only line in the sand is the law and not what some random thinks is OK or not OK in their (generally poorly informed) opinion.
I don't assist companies to do anything like that because that's not my job and I don't have clients - as I've said before. I manage the tax (and treasury & customs) affairs of the multinational manufacturing group that employs me. We don't mess around with tax havens as you refer to them because from a corporate tax point of view we have our own low tax territory - the UK I spend some of my time trying to maximise revenues in the UK at the expense of less 'hospitable' countries for that reason - but you don't have to thank me now Also because there is so much more to tax than just corporate tax (VAT, payroll, withholding, customs etc plus the associated compliance costs) and it all needs to be managed like any other major business cost.
Question for you - how do you define what is and what is not a tax haven?"I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
KingstonGraham wrote:Stevo 666 wrote:TheBigBean wrote:There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK.
Is there a perception that IOM is less likely to investigate whether his business was "in business"? Otherwise, why bother with an IOM business at all, just import it directly to the UK, because the VAT rules are the same."I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
TheBigBean wrote:Stevo 666 wrote:TheBigBean wrote:There is a Common Purse which is split between the IOM and the UK. Not sure on what basis, but I don't think it is quite as straightforward to say that Hamilton's IOM VAT declaration had no impact on the UK.
https://www.gov.im/categories/tax-vat-a ... e-sharing/The Customs and Excise Agreement between the United Kingdom and the Isle of Man has been in place since 1979, when it replaced the previous Common Purse arrangements. Under the Agreement the Island keeps its indirect tax regime largely in line with that of the UK, allowing the free movement of goods between the 2 countries.
Amongst other things the Customs and Excise Agreement removes the need for customs barriers between the Isle of Man, the UK and the EU, and makes the Island part of the European VAT territory.
The Agreement also makes provision for the Revenue Sharing Arrangement (RSA), the agreed formula by which VAT and most other indirect tax revenues are split between the United Kingdom and the Isle of Man.
The question still stands as to whether LH's declaration of % personal use and the actual are materially different. I don't believe anyone knows yet."I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
Stevo 666 wrote:Pinno wrote:Okay...burden?
Question for you - how do you define what is and what is not a tax haven?
What it says on the tin surely? (without looking it up)
A haven: place where people can place money in an account provided by an organisation within the boundaries of that geographical location which is more favourable in terms of taxable monies (?)
Perhaps even, registration of a yacht or say a business for the same purpose.seanoconn - gruagach craic!0 -
It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.0 -
TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". .seanoconn - gruagach craic!0 -
Pinno wrote:TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". .
It sounds silly, but £12 million in the private jet world buys you nothing.Postby team47b » Sun Jun 28, 2015 11:53 am
De Sisti wrote:
This is one of the silliest threads I've come across.
Recognition at last Matthew, well done!, a justified honoursmithy21 wrote:
He's right you know.0 -
Matthewfalle wrote:Pinno wrote:TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". .
It sounds silly, but £12 million in the private jet world buys you nothing.
Well get a f*cking canoe.seanoconn - gruagach craic!0 -
TheBigBean wrote:I believe Hamilton claimed 85% business use but received a full refund."I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0
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Pinno wrote:Stevo 666 wrote:Pinno wrote:Okay...burden?
Question for you - how do you define what is and what is not a tax haven?
What it says on the tin surely? (without looking it up)
A haven: place where people can place money in an account provided by an organisation within the boundaries of that geographical location which is more favourable in terms of taxable monies (?)
Perhaps even, registration of a yacht or say a business for the same purpose.
It's more about tax rates on any income - so really the question is at what rate of tax does a country become a tax haven. If we just look at at corporate tax, a lot of the classic havens have a rate of zero, but how about:-
Poland 19%
Singapore 17%
Serbia 15%
Ireland 12.5%
Cyprus 12.5%
Bulgaria 10%
Hungary 9%
Uzbekistan 7.5%
And UK 19% (17% in 2020)
?"I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
Pinno wrote:TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". ."I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0 -
The Channel Islands have not reduced Apples Tax bill - they are taxed when the money is returned to the US. Except that all changed with the developments in US tax law which will reduce the rate on remittance compensated for a deferred tax liability on profits. Nothing illegal in what they do. Or Jersey does....take your pickelf on your holibobs....
jeez :roll:0 -
FishFish wrote:The Channel Islands have not reduced Apples Tax bill - they are taxed when the money is returned to the US. Except that all changed with the developments in US tax law which will reduce the rate on remittance compensated for a deferred tax liability on profits. Nothing illegal in what they do. Or Jersey does.
This.
Apart from everything me and Steve have said these are the only factual, true, legit and kosher words on this thread.
Hat.Postby team47b » Sun Jun 28, 2015 11:53 am
De Sisti wrote:
This is one of the silliest threads I've come across.
Recognition at last Matthew, well done!, a justified honoursmithy21 wrote:
He's right you know.0 -
Pinno wrote:Stevo 666 wrote:Pinno wrote:Okay...burden?
Question for you - how do you define what is and what is not a tax haven?
What it says on the tin surely? (without looking it up)
A haven: place where people can place money in an account provided by an organisation within the boundaries of that geographical location which is more favourable in terms of taxable monies (?)
Perhaps even, registration of a yacht or say a business for the same purpose.
It really is not to do with where money flows - that is to do with invoicing. In a tech company like Apple, if you assign the patent to Jersey then you have the right to create the profit in Jersey but if you repatriate the money elsewhere - like the US then you pay tax - usually net of any tax you pay where the profits have arisen.
You do this because the value of the company is the discounted future cash flow. Reduce the cash by tax and your enterprise value goes down....take your pickelf on your holibobs....
jeez :roll:0 -
Pinno wrote:TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". .
Other way round - he would get an 85% rebate.0 -
Surrey Commuter wrote:Pinno wrote:TheBigBean wrote:It is the latest incarnation of the Common Purse
https://en.m.wikipedia.org/wiki/Common_Purse_Agreement
Note that UK customs duties go to the EU commission hence why it is not happy with the UK's more relaxed approach to collection of them. Presumably the IOM has a similar competitive advantage with regard to VAT.
I believe Hamilton claimed 85% business use but received a full refund.
Surely there are private jets out there of the £12m mark? It stinks. It stinks because no one has chartered the plane and if 85% was for business use, then the bare minimum VAT he should pay is 85% of the £3.3m surely? Arbitrary yes but there's a huge amount of leniency there.
Peanuts I know but some honesty about it's intended and actual use would help.
Why not retrospectively reclaim VAT based on proved and approved use?
Bugatti said to one of his customers regarding the Altantic Coupe having cold starting problems:
"If yo can afford a Bugatti, you can afford to put it in a garage". .
Other way round - he would get an 85% rebate.
Ha.
No such thing as VAT in 1934. Could I get an imaginary rebate on the garage I put my imaginary Bugatti in?seanoconn - gruagach craic!0 -
Deja vu...Stevo 666 wrote:And on your point about Apple, it is the Ireland and the US who are the big losers in that structure. They are both fully aware of what Apple are doing/have done, but then again Apple is not breaking any US rules otherwise the IRS would have had them pay up by now. And in the case of Ireland, the Irish government is actually defending Apple's position on this matter.
So your point about Apple is what, exactly?"I spent most of my money on birds, booze and fast cars: the rest of it I just squandered." [George Best]0