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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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If Apple Inc were a wealthy individual would its tax treatment be reasonable?

I wanted to return to a comment by Apple in the Apple Senate testimony which set me thinking:   “AOI is incorporated in Ireland; thus, under US law, it is not tax resident in the US. AOI is also not tax resident in Ireland because it does not meet the fact-specific residency requirements of Irish […]

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Apple Inc and the arms length standard

In the light of the EC letter to Ireland on Apple’s “APA” I decided to take a look at Apple Inc tax policy in the light of the EC comments. My starting point was the Financial Statements on the website, but the notes on taxes don’t tell us much about tax beyond what is described […]

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Does switching from Coal to Gas solves climate change?

Following on from my post about Coal, I thought I should comment on the spin from the Oil Industry from the UN meeting on climate change. Not surprisingly the line was that Coal should be the target and that a switch from Coal to Gas would reduce emissions. As reported in the Financial Times: Top […]

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Was admitting Russia to the OECD a mistake?

A few stories over the last few months have forced me to think again about whether OECD was right to admit Russia to the OECD and whether BIAC was right to support this proposal. I always felt uncomfortable about the process at the time, but the argument put forward was that a Russia within the […]

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What will Juncker as EU President mean for EU tax policy?

Jean-Claude Juncker has been portrayed as a man set on greater EU integration when he becomes EU President, which is why the UK does not support his appointment, but what will his appointment mean for Commission tax policy? Juncker has been Luxembourg Prime Minister, from 1995 until 2013,  when Luxembourg maintained tax policies which some […]

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Taxation and “fair share” or is it just more tax?

I had the pleasure of attending the EU Platform on Tax Good Governance last week in Brussels. There was plenty to discuss and I will write separately about the proposed subject to tax clause. The forum has representatives from member states, business and civil society. What I found interesting was the position taken by some […]

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Scottish Independence, Tax and Base Erosion

There has been a great deal of comment about Scottish Independence, whether Scotland will be better or worse off and its tax revenues as a result of the two reports published by HM Treasury and the Scottish executive which show widely differing results. I am not going to comment on the politics of government statistics […]

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