[sddfd]

This is not about taxing revenues instead of profits.

This is about taxing EU-wide profits in EU countries proportional to the revenues generated in that country.

At the moment, many big tech companies use bookkeeping tricks to make it look like all their profit is generated in, for example, Ireland, while the revenue is generated in other EU counties.

Unfortunately, Ireland has special tax rates for these companies (the legality of which is contested), so their EU-wide effective tax rate is often ~1%.

[Iv]

This is one of the main criticism about how the EU was made: freedom for funds goods and (mostly) workers to move around in the EU zone, without tariffs or constraints but no fiscal harmonization has been done.

Therefore countries with low taxes (Ireland but also Luxembourg) attract a disproportionate amount of big companies HQ. Ikea, for instance, is officially declared in Luxembourg.

Why so many people in EU rejoice about the Brexit is because UK has been one of the main force opposing fiscal harmonization (apparently London is a bit of a tax haven for financial service companies) so hopefully this kind of efforts can go forward.

[Renaud]

I don't know where you got that so many people in the EU rejoice at the defection of the UK. It is a sad state of affair that gets the rest if the EU sad and angry. I don't see what there is to rejoice about, although I'm sure that some will see it as a benefit in some narrow way.

[Iv]

That's the general sentiment in France. Too often UK has used their veto to prevent some EU-wide change or to block any initiative that was not about purely trade. Most of the people who follow EU politics think that Brexit is an economical loss but a political gain.

Here is for example an opinion piece by Michel Rocard, a former French PM (left-wing guy, really not a nationalist), before the Brexit: https://www.reddit.com/r/europe/comments/27e68h/what_rocard_...

[NicoJuicy]

Actually, UK was never part of the EU ( fully). I'm glad that's over now, i don't think UK will benefit on the long term and I hope the responsable politicians will be punished.

But at least the will be no more exceptions for participating members of the EU.

The EU was a good concept, but exceptions to members states ( not only UK, but also for Belgium eg. To much debt), made it a lot less usefull

Damned politicians...

Ps. This is not a rant against UK, but against the 'broken' execution of the foundations throughout the years.

Also it's time to send a clear message, you can't get the benefits of you aren't a member

[Boothroid]

The EU's worst nightmare is a successful UK post-Brexit. The general feeling amongst my friends and colleagues is that we are more than willing to put in the hard graft to make it happen. Anyone that thinks the UK will roll over is going to be disappointed.

[Boothroid]

Plenty of examples of the supposedly core EU members flouting the rules when it suited them also.

[petre]

People in the UK voted to join the EC, not the EU. British leadership (Margaret Tatcher) was very straightforward from the begining about not joining the EMU/Eurozone.

[NicoJuicy]

But they were in the EU, it's not about the intention of not being in. Also EC is a predecessor of the EU. It also started with the BeNeLux before that

Exceptions on joining, but not participating 100% shouldn't be allowed in the first place

[imdsm]

Remember, people voted to join the EC, and politicians then signed the UK up to the EU without asking the people. The UK was never meant to be part of the EU. The UK & US helped start the EU to prevent Europe from falling back into war, but it was never meant to engulf the UK, who as Churchill said, is too incompatible to ever be a part of it.

[zdkl]

Rejoice is indeed a bit strong, but definitely at least Schadenfreude for the foot-bullet aimed at their trust & reputation centered industries.

[Boothroid]

In your opinion. Given the fascistic bullying of sovereign nations Hungary and Poland by Brussels for merely defending their citizens' interests, perhaps the writing is on the wall.

[danmaz74]

From polls I read, except for France, most people in the EU absolutely don't rejoice Brexit. But many - me included - think that, even if Brexit is a very sad fact, at least it could help fixing this kind of problems.

[halad]

Being an economic liberal, I always thought that this was one of the main advantages of the EU. Setup shop in one country and sell to the whole single market while encouraging beneficial tax competition. I do oppose special deals for specific companies though. Ireland, please stand up to the Brussels cartel!

[henrikschroder]

The problem is that it gives large multinational companies a strong competitive edge over single-national companies, and it makes tax money bleed from high-tax countries to low-tax countries. Both of these things are also self-reinforcing, accelerating the process.

(Not that I have any solutions to these problems, I'm just pointing them out. :) )

[kemerover]

An advantage for whom? For the rich? Sure. For all other people? No.

[danmaz74]

"Tax competition" is only beneficial to the rich and to smaller states that can steal taxes from bigger ones. But of course, if you oppose free schools, free healthcare, and you favor the rich getting richer and the poor getting poorer, I understand why you like it.

[_5ysi]

Corporate tax is one of the most damaging forms of taxation in terms of the number and size of distortions it creates in an economy and it is very damaging to national competitiveness as well. But being in favor of lower corporate tax does not preclude supporting various other wealth redistribution schemes to help the poor or reduce inequality.

If the EU is more concerned about the specific case of internet giants rather than multinational firms in general, they could tax this in a much more practical way by having state run internet service providers charge these content companies for access to their markets.

[Iv]

What is the advantage of tax competition? Small countries that only host headquarters can charge very low rates: they don't have most of the expenses of bigger countries, especially if they are under no military threat by their neighbors and therefore protected by them.

[dmichulke]

Fun fact: There is no IKEA store in Luxembourg

[FormFollowsFunc]

Another fun fact: There are no Apple stores in the Republic of Ireland.

[plandis]

Yes, this is the (I think) a step in the right direction. Don't have special judgements about taxes (i.e. Apple in Ireland) because companies try to minimize the tax they pay. Actually change the laws so it's consistent for all companies.

[candiodari]

And if Hell would freeze over every summer it'd be excellent : free airco if you just dig a hole in the ground.

[otp124]

Was this comment really necessary? Couldn't you just address the OP, versus unrealistic sarcasm?

[jaredklewis]

If this system is enacted, will the benefits of staying in the EU out weigh just moving all the shell companies to the Caymans or wherever?

I wish countries would give up on corporate taxes. They are either easily circumvented, or you need a massive regulatory body to analyze all corporate transactions and determine if they are "fair."

All the same tax revenue can be gained through much better systems that are not trivially circumvented and do not create a perverse incentive for your country's companies to up and move to the nearest tax haven.

[jacquesm]

The goal is to make it pointless to use shell companies to avoid paying taxes.

> I wish countries would give up on corporate taxes.

I really wish they won't. Right now the small companies pay corporate taxes just fine, it is the big ones that play all kinds of shell games to get out from under their obligations.

[markvdb]

Much of the profit generated in the EU by these multinationals actually ends up largely untaxed in Bermuda/Cayman islands/... subsidiaries.

https://en.wikipedia.org/wiki/Double_Irish_arrangement

[candiodari]

But that would not be able to happen if it wasn't for the EU. Then import taxes would compensate.

[sfifs]

You generally can't operate a running business in EU or any other country out of the Caymans. You could have share holding companies registered there but to actually run a physical business, you have to actually have a company registered in the market (or come in as a purely imported product)

Ireland works simply because it is a member of the EU and any EU HQ business can operate anywhere else in EU.

[sgt101]

I would argue that the benefits or difficulties of avoiding taxation are dependent on the rule of law in the states where business is actually done. If the USA or EU took a political decision not to permit such structures then they would disappear.

The USA and EU don't because the benefits to their political class have so far outweighed the problems caused by a lack of revenue, and these structures have developed and proliferated rather rapidly. Additionally the political structures required to create collaborative responses have been developed in response to different issues (the necessity of supporting development in Eastern Europe after the collapse of the wall), and the alignments necessary to operate a larger system in Europe are not yet in place.

I do believe that Brexit will facilitate this, but I think that the process will have to go further to include Macron's ideas on a single budget - a greatly expanded take and disperse for the EU. This will require a huge reform of the Commission. I invite everyone to try and engage with the commission in some process or other and then judge what kind of capability you are engaging with.

I hope that the EU will devolve the distribution of central budget items to locally accountable forums, possibly at the sub national level - perhaps six for a country like France, one for somewhere like Greece. Currently I fear that the favour networks that operate in the EU institutions would greatly distort and corrupt any large fiscal rebalancing.

The big issue is that it seems that several of the national level structures in the EU would creak in the face of this kind of new set-up. Spain and Belgium in particular, but even Italy could be pulled apart by the creation of subnational entities with revenue lines independent of the national entity. Also, what would the mechanism of accountability be ? I think that this should vary according to the tradition of the region, but what are the acceptable limits or bounds on this?

Without Brexit this is simply a non-starter, I think that the UK would have been much more compromised than any other EU state by the emergence of this kind of structure, and I think that the English part of the UK would have been a real problem in terms of subnational accountability - the sovereignty of the commons would have gone and I don't see that as politically possible in England (note the other nations are less touchy about that for some reason!)

[csomar]

Can you explain what are these tricks? Asking for a friend. A link is fine too.

[rtpg]

Basic trick:

- Apple France is actually just a distributor for Apple Ireland

- Apple Ireland sells Apple France an iPhone at MSRP

- Apple France makes basically no profit because it sells "at cost"

- Apple Ireland books a profit for an iPhone sold in France

[dwaltrip]

That sounds way too easy... Is there any extra sleight of hand required? I'm surprised they can get a way with such blatant maneuvers.

[analog31]

As I understand it, there is also some monkey business related to patents. Something like this: Apple sells its patents to Apple Ireland for a dollar. Then they pay "royalties" to Apple Ireland everytime they sell an iPhone. I can't confirm where I read this.

[rtpg]

My understanding is this structure is also possible in a "legitimate" setting

For example if Apple France is really just a distributor, and they buy their products at low margins, then it is what it is

I think a lot of tax agencies simply don't have the muscle to push forward on this

[candiodari]

The most powerful politician in the EU - Jean-Claude Juncker - is personally responsible (not by himself, of course) for setting up these sorts of structures, and making sure they stay in place [1].

A quote from [1]:

"The president of the European commission, Jean-Claude Juncker, spent years in his previous role as Luxembourg’s prime minister secretly blocking EU efforts to tackle tax avoidance by multinational corporations, leaked documents reveal."

So:

> I think a lot of tax agencies simply don't have the muscle to push forward on this

No. They do. They're just prevented from doing so by the "socialists" (hah !) Europe "elected" (just pointing out that the leadership of the EU commission, the only organisation with real law-giving power in the EU aren't directly elected at all).

[1] https://www.theguardian.com/business/2017/jan/01/jean-claude...

[pipio21]

1.Have multiple subsidiaries of the same company in different countries.

2.Give intellectual property rights to one company in one country with low taxation like Ireland or a state like Maryland.

3. Make all the subsidiaries pay arbitrary patent-copyright-trademark rights to the company in Ireland-Maryland-Singapur so all the profits become zero in the different countries while transferring all those profits away.

[hkmurakami]

It's been widely reported on by major news outlets over the years. Dutch Sandwitch (now defunct?) was one of them.

[markvdb]

The double Irish with a Dutch sandwich is still available and actively being used until 2020.

https://en.wikipedia.org/wiki/Double_Irish_arrangement

[danmaz74]

In all fairness, it's not just Ireland. Luxembourg and - partially - the Netherlands also participate and benefit from this.

[candiodari]

And the guy who helped set that up - and personally made it worse by making custom tax deals for several multinationals - is now the head of the EU commission !

This will get a lot worse before it gets better.

[jeffwass]

Many American companies (including most or all YC startups) do the same, incorporating in the low-tax state of Delaware for favourable tax treatment even though the company's offices and bulk of revenue-generation are elsewhere.

[taxthrowaw4y]

I don't think this is correct. It is more about case-law and the legal support system for companies in delaware. I do not believe the companies are taxed based on which state they are incorporated in. The exception is the franchise tax fee, which is a nominal amount even to a company with only six figures of revenue.

http://www.bendlawoffice.com/2011/08/01/reasons-to-incorpora...

[immad]

If you have headquarters in California you pay tax here as well as a bit in Delaware

The reason to register in Delaware is because of business friendly courts there. I don't believe there is a tax advantage

[dogma1138]

The federal corporate tax can be up to 35%, which is the highest in the world outside of some literally banana republics.

Delaware has a corporate tax rate of 8.7%, California has 8.84.

So yes no one is incorporating in Delaware becuase of taxes, WA, TX, NV and a few others have zero corporate tax.

[uiri]

WA has business & occupation tax which functions like a corporate income tax but it is levied on revenue rather than profit.

[ericd]

Which is frequently much, much worse for companies than a higher tax on profits. Low margin businesses more than high margin businesses like software.

[rtpg]

Isn't this a misrepresentation of the global state? I think the corporate tax rate in France is 33% of profits, which isn't far from 35%

Not sure how state tax rates interact with the federal one though

[zdkl]

Keep in mind we're the last effectively communist country in the world, I'm not surprised in the least to see corporate taxes up there with the "banana republics" gp was talking about. "Social" money has to come from somewhere!

[lovich]

I don't believe I've ever heard France described as a communist country before

[dogma1138]

Yes but iirc France has a system of tax credits that reduce the liability for large companies especially. You can deduct 7% from those 33% from the payroll tax credit alone as long as you pay your workers more than the minimum wage.

[TimPC]

Delaware doesn't have unusually friendly for business courts. It mostly just has a lot of established case law. It's cheaper for businesses when they know where the lines are on most laws because of previous cases and rulings. Ambiguity is more expensive than the level of bias in most legal situations.

[uiri]

California corporate law is much worse than that of Delaware. Corporations are taxed by every state where they have to register to do business. For every corporation with a California HQ, that certainly includes the Golden State.

Corporations, such as Microsoft, which are headquartered in states with nicer bodies of corporate law frequently choose to incorporate in their home state, such as Washington.

[MarkMc]

It depends how you define profit, and to me this is absolutely about taxing revenues instead of profit.

I see profit as the 'value added' by a particular activity. At least 90% of the value created by Google, Facebook and Apple was created in California. Therefore the vast majority of worldwide income generated by these companies should be subject to the tax rates that apply in California - not Ireland, not Germany, not Spain. So Google, etc should be paying more tax - but they should be paying it to the US government, not the EU. If there is ever an EU Silicon Valley then the EU can tax the worldwide profit of those EU companies.

Personally I would like to see a rule that intellectual property is fixed to the place where it is produced and forever taxed in that jurisdiction - just like land. If you write a book or develop a new drug or software then that IP stays where it was developed.

[zdkl]

> At least 90% of the value created by Google, Facebook and Apple was created in California.

I'm trying not to be snarky but I need to say wtf.

FB & google don't make money from IP, they make money as service providers, connecting merchants on the advertisement hype train to our eyeballs.

They take money from local and transnational businesses, and present ads, aggregation and search services to individual, local, users.

How is this California related profits when I see ads for $smallbusiness in my french town? Because they host the servers there? Please. To be fair I'd concede Amazon may be different with regards to where the value they create resides but I'm sure you'll feel the same way I do when the tech giants step away from Silicon valley and it looses the sweet sweet techmonies.

This not about IP rights, corporate liberties or socialism, it's about realising when you're defending the fire that's roasting you. 'Cause google and fb don't give a F about US vs EU further than how they can leverage them to lower operating costs.

[kretor]

Seems like you are thinking the value is created by customers, while the GP thinks it is created by employees.

[sgt101]

Was it the farmer or the field? The fella that used to farm here wasn't so efficient or modern, but he paid the lord of the manors tithe, the new person is growing lots of new things, she's selling them cheap in the market.

Her toys are nicer than the family who live at the manor have ever seen, let alone owned.

She's kind of a loud mouth, keeps telling the peasants and the Baronial family that they need to change, that their ideas about life, culture and fairness are all wrong.

How does this story end.?We note that the Barons have swords, pikes, bows and arrows, a long track record of setting fire to houses and decorating them by hanging up the occupants. Perhaps though, this time, they'll simply chillax and go to the seminars that the new woman is running.

If they use option a. I expect that the next peasant in charge of the farm will be much less ostentatious, opinionated and will adopt all of the shiny new practices introduced by the last farmer. They probably won't invent many new ones... but then again are there lots of new ones to be invented now?

[zdkl]

What value do facebook developers create directly? They have crafted a network of complementary services for which I don't deny their craftsmanship, but would you argue the developers are the core business instead of the interaction between users and their product?