Feb 162016

It cannot have escaped most people in the UK that Google has just done a deal with HMRC, agreeing to pay a certain amount of money as a settlement for the tax that they are said to owe the UK Government. The Government immediately hailed this as a victory, but almost everyone else is very angry because it is too little, and because Google is a wicked multinational company that doesn’t pay its fair share.

I’m beginning to think it’s déjà vu all over again. And once again, as on all the other occasions when we hear about how a Google or a Starbucks or a Vodafone is dodging its taxes, I just pull a big woollen blanket over my ears and carry on with what I was doing. Continue reading »

The Google Tax – Some (Very) Initial Thoughts by Tax Barrister Jolyon Maugham

 International Tax, Tax Avoidance  Comments Off on The Google Tax – Some (Very) Initial Thoughts by Tax Barrister Jolyon Maugham
Dec 152014

The following is a guest article written by tax barrister Jolyon Maugham, who also writes for his own tax blog Waiting for Godot. These are Jolyon’s views on the new Diverted Profits Tax (“DPT”, or “Google Tax”) that was introduced in the recent Autumn Statement. Jolyon has kindly agreed to share his initial views on Tax Notes.

Continue reading »

Dec 032014

I am grateful to Alain Thielemans of International Tax Plaza for providing the following information about the new Consultation Paper on addressing mismatches in the tax treatment of hybrid instruments.

A hybrid is exactly that – a cross between two different creatures to produce a creature that has the qualities of both its parents. A typical example of a hybrid would be a debt security issued by a company that is convertible to equity at the option of one or both parties. You can read more about hybrids in the HMRC Manuals. Continue reading »

Vodafone and Tax Avoidance

 Corporate Tax, Tax Avoidance  Comments Off on Vodafone and Tax Avoidance
May 232013

Tax avoidance and multinational corporations have featured prominently in the news in recent weeks.

We have seen the likes of Google and Starbucks being called to appear before the Public Accounts Committee to explain their tax practices, Prime Minister David Cameron talking about the need for global action against tax evasion and aggressive tax avoidance, and even Leader of the Opposition Ed Miliband,  saying that he would rewrite the corporate tax rules (why? Doesn’t he think the new GARR will do the trick?).

Perhaps the phrase which best sums up the view of those who consider these companies to be engaging in suspect tax planning is that of Margaret Hodge, who chairs the Public Accounts Committee:

“We’re not accusing you of being illegal, we’re accusing you of being immoral”

Now it is all very well to have these debates about how and why these multinationals manage to minimise their tax bills. But what concerns me is that, reading the various press reports, it is never clear just what exactly the company involved has done that is so immoral. And if we don’t know what this is, how can we have a debate about it? Continue reading »

Budget 2013 – Buying Corporate Tax Losses – a technical analysis of the new rules on trading losses

 Budget 2013, Corporate Tax, Tax Avoidance  Comments Off on Budget 2013 – Buying Corporate Tax Losses – a technical analysis of the new rules on trading losses
Mar 262013

This is a technical analysis of the new restriction on the carry forward of trading losses when a company undergoes a change in ownership. The legislation refers to the Corporation Tax Act 2010 (“CTA 2010”).

Tax specialists will be familiar with the subject matter. For those who are not so familiar with these rules, there is another article to follow. Continue reading »

Mar 222013

The actual measure is aimed at certain “non-natural persons” and is stated to be a CGT measure. While CGT is one of the taxes involved in this anti-avoidance package, it is in substance a  penalty against wealthy individuals seeking to save stamp duty land tax (“SDLT”) when buying a home through an offshore company.  Continue reading »