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Tax and Reputation Conference – London 20 May 2013

I attended the Tax and Reputation conference on Monday in London which I thought was a very good event so thanks to Oxford University for organising it. David Gauke was , as usual clear and concise. He identified three key issues: The reputation of business The reputation of the tax system and the impact of […]

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The fall- out from Apple – will Irish eyes be smiling?

“Crikey. That was the word that ricocheted around my skull as I read the US congressional report into Apple Inc’s tax arrangements. Here are a few choice quotes: “Apple Inc established an offshore subsidiary, Apple Operations International, which from 2009 to 2012 reported net income of $30bn, but declined to declare any tax residence, filed […]

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The BEPS project and PEs (not permanent establishments)

  This article isn’t about permanent establishments but price /earnings ratios. I’ve been surprised by the fact that there has been little coverage of the impact of BEPS changes to PE ratios and hence share/stock prices.   Lets assume a group has a tax rate of say 15% (which is low by anyone’s standards) and […]

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Ernst & Young recommend transparency

E&Y have recommended that Business should be more transparent about their tax policies. Some might see this as a way to drum up more business for the Big 4! But this is what John Dixon had to say as reported by the BBC: “The public is calling for a clearer picture of the tax policies […]

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International Chamber of Commerce – Environmental and Sustainable Development

I am very pleased to have been appointed as Vice Chair for the Taxation Commission with responsibility for Environmental and Sustainable Development. This will mean engaging with UNEP and other organisations in this very important field. This sits centre stage in my belief that we need to develop a new approach to tax policy around […]

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BEPS – some questions and check the box

Reading through the BEPS paper and in particular the examples at pages 73 to 81 of the paper and listening to the debate in Paris on 26 March poses for me some interesting questions : Can business oppose the elimination of double non taxation? Can one address BEPS without changing the check the box rules? […]

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BEPS – some specific issues

The BEPS project moves forward and their barely seems to be a week when there isn’t a conference or meeting about it . But all this activity does not necessarily shed much light if the shape and purpose of the project is being conducted in a manner which could not be described as transparent. There […]

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NGOs – what is their target?

I’ve been thinking about the targets which NGOs choose in their tax campaigns in the light of the BEPS project. The two main targets have been SAB Miller and ABF. Looking at their accounts, I find this a little odd. Associated British Foods (ABF) has a tax rate of 24.8% with a benefit for rates […]

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NGO code of conduct

There has been an interesting set of exchanges about whether NGOs need to have a code of conduct for their publications about tax. I certainly think that a voluntary code would make sense. In discussing this I’ll run through a post on this subject by Martin Hearson. Martin wrote (I’ve not included the discussion about […]

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Spain and Limitation of Benefits

I’m grateful to Gomez-Acebo & Pombo for their analysis of the recent case on Limitation of Benefit for  0%. withholding under the EU Parent-Subsidiary Directive (AN November 8 2012). The case concerned dividends paid by a Spanish Co to a UK holdco which was ultimately controlled in Dubai. The decision at the Audienca Nacional (AN) […]

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