Globalisation and taxation

[campbell]

Interesting article. Boundaries for national taxation are eroding fast...

http://taxfoundation.org/article/2014-i ... ign=buffer

[RDH]

They've always been pretty fluid. It all depends on your Transfer Pricing model, whether aggressive like google or Starbucks, or more reasonable. I spend a lot of time working out how to legally bring profit back to the UK, which has a reasonably low level of Corp tax.
Tax authorities around the world are often accepting to receiving some tax rather than non tax. We operate a model in the US where we " guarantee" a 5% profit in the US, so the IRS always gets a tax revenue regardless of whether we make a real profit or a loss. In places like Brazil, it's a nightmare, they're reluctant to accept any negotiation, and even when there's agreement pm they screw you over on transaction fees to get funds out the country.

One of he more interesting(?) and challenging areas of accountancy. We also spend eye watering levels of professional fees to assist us with this.



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[campbell]

TP was part of a case study I used with participants on an HMRC deb programme I ran earlier this year. Even they found it tough