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Tax policy and developing countries – a 2016 update

I’ve been having a number of discussions about how successful the OECD project on Tax and Development has been and the challenges it faces. It was clear from inception that the inherent challenge in the project is that the interests of developed countries do not coincide with those of developing countries in many policy areas. […]

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Apple and Deferred Tax – Will the US get any tax from the Irish structure?

The debate about the state aid challenge to Ireland about Apple has been fascinating and I’ve covered some issues in a previous blog. But what has also interested me  is the discussion about when the US tax on the profits which accrue in Ireland will be paid and which government is foregoing tax to facilitate […]

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Australia’s new Multinational Anti-avoidance Law moves ahead of OECD consensus

I am indebted to Allens in Australia for their recent summary of the new Aussie Diverted Profits Tax which informs this blog. “It is aimed at 30 identified multinationals with Australian sales agency arrangements that the Government claims may artificially avoid having a taxable presence in Australia – and will seek to subject them to income […]

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Independent Commission for the Reform of International Corporate Tax

I am very pleased to have been asked to act as an expert on the Independent Commission for the Reform of International Corporate Tax which held its first meeting on 18 March in New York. The aim of the Commission is “ICRICT has been established by a broad coalition of civil society and labor organizations, […]

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Paying and Praying – Morality and Taxation

  My children have attended the local state primary school in London which is a church school. It became clear early on that there were a limited number of local children at the school because a large proportion of places are allocated based on church attendance in the parish rather than residence therein. One of […]

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Diverted Profits Tax – Centre for Business Taxation

I had the pleasure of attending this conference on Tuesday 13th January, which was as usual well planned and organised by the CBT. It was a fascinating couple of hours as much for what was not said as for what was. A number of speakers quoted to support their case, but I felt I was […]

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A “Google tax” or are royalty arrangements “artificial avoidance”?

The Autumn Statement in the UK on 3 December saw the announcement of a “Google Tax” to come into effect on 1 April 2015 (no it’s not a joke). Details are sketchy but its described as “25% tax on profits generated by multinationals that are shifted out of the UK”. I thought I would put […]

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Luxembourg tax rulings and the EC Commissioner

The coverage of Mr Juncker’s suitability for a lead role in the BEPS project has been fascinating during the G20 summit in Brisbane. In my blog of 30 June, I ended it by saying: “This isn’t a poacher turned gamekeeper, it looks more like the poacher in charge of the gamekeepers.” A number of politicians […]

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Stock Markets, Pension funds, PE ratios and tax avoidance

“The pension fund community has been surprisingly quiet about aggressive tax avoidance engaged in by the companies they invest in, but there are signs that their attitude towards corporate tax is changing.” So reports the FT. The lack of interest in corporate tax by pension funds has long surprised me, given the long term focus […]

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Ireland’s tax rate and Apple

I’ve written about the arrangements which Apple has in Ireland and their need to comply with the arms length principle. Some recent coverage has revealed concerns that some countries still have as a target the corporate tax rate in Ireland rather than arrangements or rulings. This would be the wrong target and the review should […]

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