4 ms·

Both Ireland and Luxembourg have legitimate activities: Irish whiskey isn’t a big deal compared to tech, but there’s no real reason to ban it. Defining a line i

by bertil 5y ago

Both Ireland and Luxembourg have legitimate activities: Irish whiskey isn’t a big deal compared to tech, but there’s no real reason to ban it. Defining a line is hard, especially when the country’s traditional advantage _is_ finance, like it is in Luxembourg, even outside of tax-optimisation. It’s easier to have rules against countries with less credibility, but then again, you risk making things complicated for Seychelles, Curaçao, St-Martins. It’s easier to define a minimum tax so that they don’t have to pick between tourism and tax optimisation.

sumedh 5y ago
> Both Ireland and Luxembourg have legitimate activities: So those countries need to decide if they want to support legitimate activities or legitimate activities with fair tax policy approved by the US. If they dont like US's demands they can stop trading with US but we know they are not going to do that.
- foepys 5y ago
  In that case the US should first handle Delaware before throwing the first stone.
  - sumedh 5y ago
    Yes they should but they are probably not going to do anything.
dkersten 5y ago
Maybe an import duty needs to be applied. Importing the Irish whiskey will incur a duty. Google US paying a 100% license to Google Ireland should also incur a duty charge for importing the license from Ireland. Something like that, anyway.
- mohanmcgeek 5y ago
  Yes! Exactly this. Except the reason it's not done today is because back in the 90s, people argued that it's not possible to tell if/when services/IP crossed borders because there's no fixed port of entry. (They were making this argument because software CDs were subject to import duties but downloads were not and that they were unfair) Today it's still the case and services/IT are not subject to duties.. but I think large licensing agreements like this should definitely attract import duties
  - dkersten 5y ago
    The solution is simple enough: look at the companies books, if money is leaving the country, duty is charged unless it can be accounted for by something else (like the existing duty on physical goods). IRS: Hey Google, you said you made this much money, so you owe us tax. Google: No, see, here we paid it to Google Ireland as IP license fees, so we in fact made $0 IRS: Great, you owe us duty on that payment
    - selimthegrim 5y ago
      All rise, court is now in session. The honorable Lina Khan presiding. The case of U.S. vs. 10 Billion Wrapped Individually Marked Bills.

by bertil 5y ago

sumedh 5y ago

> Both Ireland and Luxembourg have legitimate activities: So those countries need to decide if they want to support legitimate activities or legitimate activities with fair tax policy approved by the US. If they dont like US's demands they can stop trading with US but we know they are not going to do that.

foepys 5y ago
In that case the US should first handle Delaware before throwing the first stone.
- sumedh 5y ago
  Yes they should but they are probably not going to do anything.

dkersten 5y ago

Maybe an import duty needs to be applied. Importing the Irish whiskey will incur a duty. Google US paying a 100% license to Google Ireland should also incur a duty charge for importing the license from Ireland. Something like that, anyway.

mohanmcgeek 5y ago
Yes! Exactly this. Except the reason it's not done today is because back in the 90s, people argued that it's not possible to tell if/when services/IP crossed borders because there's no fixed port of entry. (They were making this argument because software CDs were subject to import duties but downloads were not and that they were unfair) Today it's still the case and services/IT are not subject to duties.. but I think large licensing agreements like this should definitely attract import duties
- dkersten 5y ago
  The solution is simple enough: look at the companies books, if money is leaving the country, duty is charged unless it can be accounted for by something else (like the existing duty on physical goods). IRS: Hey Google, you said you made this much money, so you owe us tax. Google: No, see, here we paid it to Google Ireland as IP license fees, so we in fact made $0 IRS: Great, you owe us duty on that payment
  - selimthegrim 5y ago
    All rise, court is now in session. The honorable Lina Khan presiding. The case of U.S. vs. 10 Billion Wrapped Individually Marked Bills.