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Financial Transaction Tax and Extraterritoriality

I’ve always maintained that business and taxpayers should oppose any attempt to introduce extra territorial provisions in tax – the reason being that it increases the likelihood of double taxation and its detrimental economic effect on growth. Its also “taxation without representation” and that is not a firm foundation for any international tax system which […]

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European Commission probes “tax deals with Multinationals”

There are reports that Brussels is probing Ireland, Luxembourg and the Netherlands over their tax legislation and rulings for multinationals – is this a great surprise? Well no for a number of reasons. The Commission needs to be seen to be doing something in the G20 framework on tackling tax avoidance, to avoid being sidelined that is […]

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Netherlands tax treaty policy – anti abuse and substance

The Netherlands has announced a review of it tax treaty policy with developing countries. It appears that this is a political judgement which balances the fact that the Netherlands doesn’t want to give up its attractiveness as a holding company location but has been under pressure and scrutiny about the ability to flow income through […]

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Vodafone/Verizon and the tax which wasn’t!

I watched the BBC news reporting last night of the disposal by Vodafone of the stake in Verizon with despair and dismay. I’ve now read the blogs by Robert Peston on this and I’m even more amazed. I’ll quote Robert: “Which of course begs the question how much capital gains tax Vodafone will pay to the […]

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What is the right tax rate for fracking in the UK

Martin Hearson has written an interesting blog on the proposed tax regime for gas produced by fracking in the UK and questioned whether it is necessary to offer the incentives for this activity. Britain’s fracking tax incentives: do they pass the test? He says: “First, will there be a published, transparent analysis of the revenue expected […]

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The Beps report – 19 July 2013 – “You don’t need a weatherman to know which way the wind blows”

Building on my comments on 15 July, I’m now going to look at what has been said. It is pleasing that my high level summary appears to have been fairly accurate. What I’m going to do today is to focus on the what (what is proposed) the when (the timetable) and the how of BEPS […]

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BEPS workplan – “what is to be done”?

July is traditionally a month for revolutionary activity, the US in 1776 and the French – twice! – in 1789 and 1830. So is July going to be a revolutionary month again in Paris in world tax policy with the anticipated publication of the Base Erosion Profit Shifting work plan this week? Well we have already seen […]

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Is the UK patent box regime fair tax competition?

At the Stockholm conference there was a bit of a spat between Theo Keijzer and Will Morris over whether the new patent box regime in the UK was fair or unfair tax competition. References were made to the three wars fought between the Dutch and the English in the 17th century between (1652 – 1654, […]

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Why do US Companies pay so little tax on foreign profits? Does this give them a competitive advantage?

The debate continues as to why US Companies pay such low tax on their non US earnings in the press in Europe. As the following quotes are from an article in the Wall Street Journal on 1 July 2013 show the facts are fairly clear. “A government watchdog agency found that large , profitable US […]

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Responsible business: a reaction to BEPS

This post builds on some comments I have made in a number of meetings and my reflections on listening to the G8 transparency meeting, the European Commission, the OECD and various governments over the last month. As the date for the publication of the BEPS workplan approaches Business needs to think about its response. It […]

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