Five people who were missing from the Global Tax 50

We’re invited to comment on International Tax Review’s Global Tax 50. It says a lot about these annual trade press lists that four years before I appeared in the International Tax Review list I had featured in its equivalent in Drapers, which covers the fashion industry! Still, it’s a fun game, so let’s play it.… Continue reading Five people who were missing from the Global Tax 50

What makes Bradley Wiggins and Jimmy Carr different?

Compare and contrast: I had a small investment in Twofold, following guidance from my professional advisers. I had, however, claimed no tax relief of any amount in regard to this investment. Given the concerns raised, I have now instructed my advisers to withdraw me from the scheme with immediate effect. That’s Bradley Wiggins in an… Continue reading What makes Bradley Wiggins and Jimmy Carr different?

On the contribution of corporate tax scandals to debate

My post last Tuesday provoked a disgruntled email from a tax academic. “I do not feel qualified to say whether the Starbucks royalty is excessive or not,” wrote my correspondent. “I think that is HMRC’s job. Do you feel qualified to say it is excessive? If so, on what evidence?” This is a fair question,… Continue reading On the contribution of corporate tax scandals to debate

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.

Has Starbucks dragged Fairtrade into a tax avoidance scheme?

In the aftermath of the excellent Reuters story about Starbucks’ tax dodging in the UK, some columnists (best pun: ‘Starbucks makes a mochary of tax law’) have picked up on the apparent hypocrisy of the biggest buyer of Fairtrade coffee in the world also employing tax avoidance schemes. Take note, however, that the link is… Continue reading Has Starbucks dragged Fairtrade into a tax avoidance scheme?