EU Regulators, Apple Tax - effect on Ireland PLC? ( on foot of McDonalds Decision )

robut

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McDonald's to move international tax base to UK amid EU scrutiny | Reuters

McDonald's Corp said on Thursday it would move its international tax base to the United Kingdom from Luxembourg after coming under increased scrutiny from European Union regulators over its tax arrangements in the small country.

McDonald's said it would create a new international holding company domiciled in the UK that would receive the majority of royalties from licensing deals outside the United States.

The reorganization comes amid an investigation by the EU into what it says are sweetheart tax deals that smaller states in the bloc offer to multinational companies to lure jobs and investment.

In August, the EU ordered Apple Inc to pay Ireland unpaid taxes of up to 13 billion euros ($13.8 billion), ruling that the iPhone maker had received illegal state aid.
So .. Interesting one this. McDonalds moving headquarters from Luxemberg to Brexit UK .. out of the EU. ( Google and Facebook recently announced UK expansion. )

Now we have a REAL effect of the Apple Tax ruling going forward for Ireland PLC pitching for FDI to headquarter here?

I didnt see this one coming to be honest as an effect of Brexit, so to speak. Because UK will be outside this EU regulation system.

Is this not much of a deal? OR could we see alot more following McDonalds, inc from here to escape EU tax regulation? Could this be another factor to inch Ireland, possibly unwillingly, toward #Irexit?

( the Google, Facebook UK expansion - https://www.theguardian.com/business/2016/nov/21/google-facebook-brexit-uk-technology-sector-skills )
 


flavirostris

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That's really interesting. I always thought the government were in a bind re. Apple because they want to keep those multinationals sweet. Apple employ 6000 or something in Ireland. It's easily the biggest employer in Cork.

So they would think long and hard before doing anything to piss them off.
 

blokesbloke

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More fallout from the dire Brexit decision I see.

If only I had voted Remain!
 

venusian

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That's really interesting. I always thought the government were in a bind re. Apple because they want to keep those multinationals sweet. Apple employ 6000 or something in Ireland. It's easily the biggest employer in Cork.

So they would think long and hard before doing anything to piss them off.
Tax dodging MNC's must be brought under control and pay a fair share of tax wherever they are domiciled. Its rather simple what McD's are up to in the UK

Previously a number of international companies have shifted their corporate registration or primary tax residence to the UK since Britain relaxed its rules on the taxation of companies' foreign subsidiaries in 2012. E.g. the likes of U.S. lock maker Allegion (ALLE.N), U.S. insurer Aon (AON.N) and Italian tractor maker CNH Industrial (CNHI.MI).

Under UK rules, profits earned by overseas arms or a UK-registered company are effectively exempt from UK tax even if the income is untaxed.

The tax dodging scam works like this, it allows companies shift profits out of the UK before being taxed and then allows companies bring the money back tax free. Nice eh? All it does is enrich shareholders and makes the wealthier, well, wealthier whilst contributing nothing from their profits to society. The more the EU does to crush MNC tax dodging the better !
 

storybud1

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More intellectual/Copyright/ rights fiddling by the boyos, profit tax needs to be utterly re-examined as it was the main reason for closing factories in the US and outsourcing in the 90s.

nobody can really come up with a simple answer as it would involve so many complications as cross border trade improves relations and if suddenly massive tariffs were introduced it would be back to protectionism and we would lose a lot of common ground.

Big companies know this and use it to their advantage, it's just business, it's not socialism,,
 

Strawberry

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Tax dodging MNC's must be brought under control and pay a fair share of tax wherever they are domiciled. Its rather simple what McD's are up to in the UK

Previously a number of international companies have shifted their corporate registration or primary tax residence to the UK since Britain relaxed its rules on the taxation of companies' foreign subsidiaries in 2012. E.g. the likes of U.S. lock maker Allegion (ALLE.N), U.S. insurer Aon (AON.N) and Italian tractor maker CNH Industrial (CNHI.MI).

Under UK rules, profits earned by overseas arms or a UK-registered company are effectively exempt from UK tax even if the income is untaxed.

The tax dodging scam works like this, it allows companies shift profits out of the UK before being taxed and then allows companies bring the money back tax free. Nice eh? All it does is enrich shareholders and makes the wealthier, well, wealthier whilst contributing nothing from their profits to society. The more the EU does to crush MNC tax dodging the better !
If their Brexit plan is to allow US multinationals to use them as a haven to hide tax dollars I think they might fall foul of a certain Donald Trump.
 

Supra

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McDonald's to move international tax base to UK amid EU scrutiny | Reuters



So .. Interesting one this. McDonalds moving headquarters from Luxemberg to Brexit UK .. out of the EU. ( Google and Facebook recently announced UK expansion. )

Now we have a REAL effect of the Apple Tax ruling going forward for Ireland PLC pitching for FDI to headquarter here?

I didnt see this one coming to be honest as an effect of Brexit, so to speak. Because UK will be outside this EU regulation system.

Is this not much of a deal? OR could we see alot more following McDonalds, inc from here to escape EU tax regulation? Could this be another factor to inch Ireland, possibly unwillingly, toward #Irexit?

( the Google, Facebook UK expansion - https://www.theguardian.com/business/2016/nov/21/google-facebook-brexit-uk-technology-sector-skills )
The ruling wasn't the problem it was the illegal state aid that was the problem.

This could be a bump for UK in brexit talks. The UK need to tread carefully.
 
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It really is easy to stop.
All trading activity of a MNC in a country is taxable in that country, any licensing, intellectual property payments or other intangible (non physical goods) charges are allowable against tax up to 5% of turnover.
 

Analyzer

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If Starbucks is thinking about the same move, then surely Ruthie will make her move and occupy the barista machines.......

Surprised the Trots have not started a protest yet outside the McDonalds in Blanchstown SC.
 

robut

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https://www.bloomberg.com/graphics/2016-apple-profits/

And from this article ... jaw drop :D

Using Irish subsidiaries to funnel all that cash into Treasuries may help explain a bond-market curiosity that’s emerged in recent years: how Ireland, a nation of less than five million, managed to amass $271 billion of U.S. government bonds, based on data compiled by the Treasury, and become America’s largest foreign creditor, after China and Japan.
Surely the gig is up?? And if so, using CIA parlance, what sort of blow back can we expect coming our way??
 
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Analyzer

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Punching above our obese unhealthy beerbellied weight in the US Tbond market ?
 

Lumpy Talbot

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No
I was just commenting a few days back on an economics thread that the reason I had decided the entire western economic system was basically fake was because of the intertwining of multinational tax arrangements with various national accounts- in that case I had pretty much bust out laughing a year or two back when Belgium popped up in international stats as the main buyer of US debt.

There was absolutely no economic or socio-political reason for that to be a normal economic indicator and now we have Cathleen Ni Houlihan digging deep for Hank and Jean-Jo.

Apparently.

US government paper just seems to be an enormous bump in the carpet wandering around the world like a mole trying to surface under someone's axminster.

Maybe it is that massive German CDF and CDO debt from about five years ago that burrowed away somewhere in the sea bed and is now trying to rise disguised as US government paper in Roscommon.

The International Economic system in the west went surreal in the mid-noughties and only Salvador Dali can save us now.
 

toughbutfair

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Ire co has turnover of 10m, spends just 2m on r&d , no other expenses - how much tax should they pay?

Deduct the r&d so profits 8m , new tax rate here of 6.25% (received little criticism) so that is tax of 500k, oh wait - we say that we will pay a quarter of their r&d spend so they get a credit of 500k . Tax due =zero
 


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