Adapted from some comments I made on an academic paper (unpublished, so I can’t link). What has international tax got to do with “open source” software? Well, maybe nothing, but let’s run with it for a minute.
Category: United Nations
A great letter in this morning’s FT from a tax lawyer demonstrates not one but two points about the transfer pricing of royalty fees. The first is the way in which companies game the system:
The role of the tax expert was to identify the highest level of royalty that could be defended in attritional correspondence with the Inland Revenue. The lawyer’s role was to reach for the intellectual property precedents and draft licensing agreements, which bore the imprimatur of arms-length contracts although they were in reality no such thing.
Sometimes discussion of transfer pricing by campaigners obscures the difference between the blatent use of prices that are much lower or higher than should be permitted (this is true ‘transfer mispricing’, which is more akin to fraud) and the more common manipulation of prices to get the best tax position possible within the ‘arm’s length’ range.
Would a new article in the UN model tax treaty be a ‘fundamental change’ to international tax?
The most lively debate in the first two days of the UN tax committee meeting ended with the decision to start work on a new article for the UN’s model tax treaty that would allow developing countries to levy a tax on payments made to overseas providers of ‘technical services’. The advocates of this position… Continue reading Would a new article in the UN model tax treaty be a ‘fundamental change’ to international tax?
Why I love the United Nations tax committee, part 2
An interesting exchange at the United Nations tax committee on Monday, tinged with a certain irony. In the run up to the meeting, the United States Council for International Business had written a pretty angry letter to the Committee, copying in half the US Treasury, complaining about the committee’s new practical manual on transfer pricing… Continue reading Why I love the United Nations tax committee, part 2
Why I love the United Nations tax committee, part 1
International tax, the way countries coordinate and negotiate tax rules between themselves, is often talked about as if it’s about finding technical solutions to technical problems. But it’s not. Just as the tax system inside a country is at the absolute core of its political debate, so you can look at international tax and see… Continue reading Why I love the United Nations tax committee, part 1
Martin Hearson 