And now for something completely different! 2 hours on international tax starting w @SolPicciotto @Ezenagu @martinhearson & Mike Durst on allocation of MNE income #ICTD19pic.twitter.com/GmCD63tr6F
Business and sustainable development. Accountability. Tax. Feminist test case. Media: Tom Gardner at Slater & Gordon 0207 657 1690 press@slatergordon.co.uk
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And now for something completely different! 2 hours on international tax starting w @SolPicciotto @Ezenagu @martinhearson & Mike Durst on allocation of MNE income #ICTD19pic.twitter.com/GmCD63tr6F
Sol is giving the 20 minute history of the international tax system, the ALP, transfer pricing, BEPS, simplified methodspic.twitter.com/S3NlhmghY0
Brazil uses simple method. No transfer pricing. Two types of company: importing and exporting with fixed margins. Rough justice, but simple to administer.
. @Ezenagu makes the case for safe harbours: secure revenue, reduce cists and uncertainty on both sides, equitable treatment of companies within the covered industriespic.twitter.com/Vfwvzsxzz6
... And the case against from @OECDtax: fears of double taxation, breaking ALP. But support from many countries and companies. Now OECD gives cautious, limited support
Size thresholds for SMEs and small transactions are common, but Africa's large enterprises tend to be smaller. So sectoral safe harbours, sectoral APAs may be useful for most African countries
Mike Durst suggests a turnover based alternative minimum taxpic.twitter.com/6PmGu03Jmd
Mike Durst's proposal for a 1% AMT on turnover .... 18 countries do something like this (particularly in Francophone Africa) but many undermine it with low caps on the amount & tax holidays. How is it imposed in practice? http://www.ictd.ac/durst-book pic.twitter.com/a6eqB0UUhK
. @VAdegite supports safe harbours as a good tool. Avoid testing every transaction. Set a safe range e.g. For routine support services
Revolution or evolution? @SolPicciotto say its a waste of capacity to train people up on transfer pricing on OECD method or adopt another short term method on expectation of wider change. Is it cost effective? Alternatives: royalties, telecoms tax, AMT and TP using simple formula
Mike Durst: would an AMT encourage companies to pay no more than the safe harbour? Yes but companies already seek to lower their taxes. The AMT takes away incentive for tax avoidance
Q: What's the tax gap? Sol says size of revenue gains is not important, the prize is to reduce the complication of the transfer pricing systems. Would be good for investment certainty
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