Number of the Day

The Irish Times today, page 2:

$36m

Amount Apple paid in Irish taxes between 2004 and 2008, despite the 12.5% rate meaning they have paid in the region of $890m

Editorial: Apple’s lucrative tax loophole

…figures obtained by The Irish Times show that between 2004 and 2008 the consumer electronics giant reduced its Irish tax bill by over €850 million…

Yes, because the profits of a US company selling products designed in the US, manufactured in China and sold to customers in Australia actually should be taxed in Ireland (only we’re not sure whether it is in $ or €).

Comments

comments

59 thoughts on “Number of the Day”

  1. Bono may be able to help clarify matters!

    http://www.theguardian.com/music/2013/sep/22/bono-campaigner-u2-global-poverty

    “The other persistent criticism is about the band’s decision to offshore part of their income through the Netherlands to avoid tax. Was it not hypocrisy for you to try to hold the Irish government to account for its spending while going through fairly exhaustive efforts to avoid paying into the Irish exchequer yourself?

    It is not an intellectually rigorous position unless you understand that at the heart of the Irish economy has always been the philosophy of tax competitiveness. Tax competitiveness has taken our country out of poverty. People in the revenue accept that if you engage in that policy then some people are going to go out, and some people are coming in. It has been a successful policy. On the cranky left that is very annoying, I can see that. But tax competitiveness is why Ireland has stayed afloat. When the Germans tried to impose a different tax regime on the country in exchange for a bailout, the taoiseach said they would rather not have the bailout. So U2 is in total harmony with our government’s philosophy.

    But surely you have given up some authority in doing so. Was it worth it?

    I think for many reasons people have taken a dislike to our band and to me. This is another one. I have worked as an activist for all my adult life, and I think overall that no one can doubt we have been pretty effective. You can criticise me for a lot of things, but probably not for my commitment of time and energy to this. I think some of the people who criticise us in Ireland and America have a history that you can trace back to our opposition to Noraid. A lot of the others probably hate our music. And a lot of other people probably have a point…”

  2. Regardless of whether the lacuna in the tax laws is an Irish, US or Netherlands lacuna, this issue is not going away. Neither should it.

    The reality is that the beneficiaries of low worldwide corporate taxes are by and large the wealthy and very wealthy share owning public and institutions-including pension funds. [Poor people don;t have pension funds]

    Large corporates, and indeed some small ones, believe that they are doing society a favour by providing employment, and by virtue of that employment creation, have almost a moral right to be exempted from tax contributions on profits.

    It is time the corporate sector worldwide, started to contribute a reasonable share of its profits to the benefit of society, as individuals are required to do in most countries.

    Ireland’s refusal to contemplate the Financial Transaction Tax, a modest tax gathering proposal on financial gambling, does not stand scrutiny, and is primarily the result of lobbying by powerful interest groups.

    But, as Bono says above, “It is not an intellectually rigorous position unless you understand that at the heart of the Irish economy has always been the philosophy of tax competitiveness. Tax competitiveness has taken our country out of poverty… So U2 is in total harmony with our government’s philosophy.”

    And who could argue with Bono.

  3. @ Joseph Ryan

    Two informative links!

    http://www.nytimes.com/2013/05/29/business/the-trouble-with-taxing-corporations.html?_r=1&

    http://appleinsider.com/articles/14/02/14/apple-distributed-another-26-billion-in-dividends-to-shareholders-on-thursday

    The FTT, as the name implies, is a tax on transactions, not profits. As to the latter, as far as corporations are concerned, their employees pay tax, their employer pays social welfare contributions and their shareholders pay tax on dividend income in accordance with domicile rules.

    But the basic question relates to where corporation profits, if they are to be taxed, are to be attributed. This is as complicated IMHO in the case of U2 as in the case of Apple and in many other sectors in the modern international economy. A revenue sharing arrangement on some agreed basis would be the obvious solution. The likelihood of it happening against the current international background is practically zero.

  4. The other interesting thing about the trend of technology based NMCs in aggressively reducing their tax bills is that most are actually in the business of destroying jobs.

    How many programmers/engineers were required to make Tescos self checkouts? An order of magnitude less than the resultant loss in sales assistant jobs. On line banking is similar.

    Google has been at the forefront of self driving cars. Which should hit our roads in no more than a decade. Even if they employ 1000 programmers on the project, which is very unlikely, how many taxi men globally will be out of a job? How many artic/lorry drivers? Will the car insurance industry be required? After all, why would one need insurance, these things will be infinitely safer than human drivers. In fact self drving will likely be seen by society as drink driving is seen today.

    Admin staff, researchers will be on the scrap heap soon. Software is getting better and better with natural language, ‘Siri’, ‘Google now’ etc… Soon enough reports will be churned out faster than any undergrad or legal assistant could do it.

    Accountants, who’ll need them in 10 years?

    Maybe what, two decades before a robot does your Transplant Surgery without a human.

    Most people think in a linear fashion about advancement in technology, but the change is exponential, and starting to wipe of jobs/sectors of the economy at a faster rate than they’re adding new ones. Big lotto gains for good programmers and their employers/companies/sharholders. Very little for society apart from stopping ministers claiming for employing a driver, though our lot would probably try anyway.

  5. @Seamus Coffey

    ‘… because the profits of a US company selling products designed in the US, manufactured in China and sold to customers in Australia actually should be taxed in Ireland (only we’re not sure whether it is in $ or €).’

    Global issues demand Global Solutions. Who do I phone in Global?

    @U.S. Congress & Senate

    Over to you babies; not to worry about losing those ‘hefty’ corporate campaign donations. Ahhh Didn’t think so!

    @all

    Who is this Bono?

    @all at all

    Best figure of the day: Blind Biddy stepping it out in Kharkov!

  6. I think it might be an opportune time for the three spinners,Enda,Eamon and Bono to pour themselves a large glass of double Irish and listen to an old Irish melody dedicated to them by Nana Mouskouri;

  7. you all get it wrong.

    Why should some self appointed do-gooder like Bono be taxed like the ordinary stupid ilk like us? After all, they are the “creative class” to be admired and worshipped. And after all they do they occasional “Gala Dinner” to show the polloi their place, and give them some scrums of their choosing.

    Why should these lovely people pay tax beyond the expenses for the guards and gardeners of their gated communities?

    low life Germans with machine grease under their finger nails and not being able to talk the Queens English, not willing to pay whatever INET financing speculator needs ? Why do they even dare to talk back?

    But rest easy, now the truth is out, thanks to the Onion network:

    Swift Boat Veterans For Truth Clear John Kerry After Exhaustive 9-Year Investigation

  8. FYI on Kharkov:

    “With the final destruction of German forces at Kharkov, the Battle of Kursk came to an end. Having won the strategic initiative, the Red Army advanced along a 2,000 kilometres (1,200 mi) front.” Taylor & Kulish 1974, p. 171.

    ‘Stalingrad was the end of the beginning; but the battle of Kursk was the beginning of the end.’ Winston Churchill

    http://en.wikipedia.org/wiki/Battle_of_Kursk

    p.s Blind Biddy’s great aunt Katharina [on her mother’s side – Kitty at home] eloped, aged 17, with a Cossack during the Eucharistic Congress. She commanded a tank at the Battle of Kursk and, following promotion, was the first tank commander into Kharkov in late 1943 where she is held in the highest esteem to this day. A long story – tbc

  9. Viktor Frankl the holocaust survivor said, “even within the narrow boundaries of the concentration camps he found only two races of Men to exist: decent and unprincipled ones. These were to be found in all classes, ethnicities, and groups.”

    With businesses the same principle applies, they are either “decent or unprincipled” and god knows we proliferate enough of the latter types in Ireland.

    We also allow unprincipled corporations to fool us with words like “tax avoidance”. We enable them, thereby making it easier for them to be “unprincipled” and then we say that being “unprincipled” is legal, because it is only tax avoidance.

  10. Aren’t there similar tax avoidance schemes in Ireland for family farms and businesses on inheritance? If the money stays in the business then there’s less tax. Almost none, in fact. Seems popular.

  11. If Ireland taxes Apple all the music on your I-tunes account may be at risk. The music might stop immediately. Very like the banks and credit.

  12. and google search might stop giving you back results, the internet might break, much like the way ATMs nearly stopped working back in the day.

  13. So Ireland is completely blameless in all of this Seamus? No sins at all, either of commission or omission?

  14. Michael Noonan, finance minister, announced last month that civil servants in the Department of Finance are working on what will effectively be a propaganda document, due for publication at the month end, to give some intellectual heft to the risible claims made by the Irish Government on tax avoidance in the past year.

    The claims in respect of the tax system on transparency, statute based and so on, are contrived to divert attention from the truth.
    Enda Kenny revealed his own confusion on the Government’s wobbly defences last Friday when he said the OECD is to tackle “statelessness” by multinational companies.

    Apple Sales International is an Irish company used for tax avoidance, wherever it’s managed from.

    Tax advisers and ministers conveniently pretend that the Irish authorities have no responsibility for them.

    In 1999 under pressure from the EU, it was planned to have all Irish companies tax resident. However, an exemption was made under pressure from the American Chamber of Commerce to maintain the offshore facility for US companies. So the Finance Bill of that year provided that an offshore company which was tax resident in a double-tax agreement country could maintain its status while new non-tax resident companies could be setup if it was related to an existing firm with Irish operations.

    The use of the unlimited mailbox companies in island tax havens enabled big US companies with operations to say that foreign income was routed through ‘Irish companies.’ In Apple’s case, it decided that the Irish companies would be independent of any tax jurisdiction.
    It is true that Ireland gains little from tax cheating but at some point, the US tax system will be reformed and a territorial system where companies are only liable in the US on US profits, would only be viable if there was a disincentive to shift profits to non-tax or low tax countries.

    The risk for Ireland is that a minimum foreign tax would be introduced that would be greater than the Irish headline rate of 12.5%.

    From the 1970s when Dublin supporters on Hill 16 unfurled a banner with ‘Come on the Taxpayers’ during a Dublin-Kerry all Ireland final, the Irish Revenue became aggressive in tackling personal tax evasion, imposing punitive levies and publishing the names of tax dodgers.

    Today, wonder what would happen a local company if it booked big charges to shift profits to Bermuda?

    Seamus replied on Twitter to the piece below:

    Partially agree. It is US tax “avoidance” as provided for by US law. We enable its use. Also agree re impact of Google on stats.

    http://www.finfacts.ie/irishfinancenews/article_1027392.shtml

  15. It’s good that Bono feels uncomfortable about his tax arrangements.

    Last September at the Clinton Global Initiative in New York, he called on resource companies in Africa to be transparent about their payments. Some of them use the same Dutch tax structures as himself.

    Bono’s hypocrisy on Africa, corporate tax avoidance in Ireland

    Companies like Apple are huge beneficiaries of globalization and in the US the company exhibits the positives and negatives of that development.

    It employs about 50,000 in the US and most of the staff are not well paid. By comparison, General Motors had over 618,000 employed in the US in 1979 – in well-paid jobs

    About 30,000 work in Apple’s retail stores with the pay typically at $25,000. There are about 8,000 in support and 12,000 developers who are the elite.

    Apple had $158bn in cash and near cash securities at end 2013.

    The tax avoidance benefits mainly goes to the owners of capital and according to a Brookings paper, by 2010, the labour share of the bottom 99% of taxpayers had fallen to approximately 50% from just above 60% prior to the 1980s.

    The companies benefit from both competition within the US and internationally for their jobs as well as public education spending.

  16. Michael,

    how many of those 12000 developers are actually “elite”, as in, lets say paid at least 2x (10% of population) the median wage of 55 k$/yr.

    Or should we be more stringent and ask for 3x median (3% of population) with that banker in mind, who complained, that you cant live on 250k in NYC?

  17. On the issue of who benefits from current international corporation tax arrangements – or, rather, the lack of them – this Wiki entry (subject to the usual qualifications) on the payment of dividends may be of interest.

    http://en.wikipedia.org/wiki/Dividend_tax

    (The argument about the double taxation aspect reminds me of the scene from Some Like it Hot where the Mafia boss is detailing the Organisation’s tax liability and adds “except we aint’ payin’ no taxes”).

    The debate in the US, nevertheless, brings out the fact that an argument can be made that corporations should pay no tax on their profits and that retaining profits either at home or abroad and building up huge cash reserves are a legitimate aspect of a rapidly changing international business environment, especially in the new technological areas.

    Countries generally seem to have found a range for tax on dividends (20% to 30%) and, presumably, could also agree a common corporation tax range. But on what basis? Even within the EU, agreeing the proposals on a Common Consolidated Corporation Tax Base (CCCTB) is proving problematic.

  18. @ francis

    Average pay for an engineer is about $125,000 – – so you’re right. They’re all not coining it, as we say.

    @ DOCM

    Abolishing CT would be a bonanza for company executives and shareholders.

    In 2004 when the rate was cut to 5% to promote repatriation, most of it was used for share buybacks, dividends and executive pay hikes.

    Some companies cut jobs and research spending.

    Only about half of Americans own stocks, including those in retirement accounts.

    Five per cent of Americans are responsible for almost 40% of consumer spending – – there is only so much each of them can eat and drink in a day!

    Who will pay new taxes to fund job subsidies for wealthy companies and public education to provide a source of talented workers?

    American plutonmony:

    http://www.finfacts.ie/irishfinancenews/article_1027224.shtml

  19. and in other news economists blow away by the job numbers,spring is in the air!
    http://money.cnn.com/2014/03/07/news/economy/february-jobs-report/

    gosh what a s**thole cant even watch a movie nominated for best picture,sounds like Ireland in the 50’s.Must be difficult to provide informed commentary if ya cant even watch the top flicks.Oh well maybe theres a pirated copy knocking around the back streets and alleys.
    “KUALA LUMPUR — “The Wolf of Wall Street” may be funded by Malaysian producer Riza Shahriz Abdul Aziz’s firm, but movie fans here will not get to watch the Hollywood show after it was reportedly banned by local authorities.”

    http://www.malaysia-chronicle.com/index.php?option=com_k2&view=item&id=215622:to-shield-najib-rosmah-from-sons-scandal-msia-bans-screening-of-wolf-of-wall-st&Itemid=2#axzz2vTZ2Wm7U

  20. @ MH

    The subject is corporation tax, not inequity between income groups which I agree has become intolerable. One way of tackling the latter would be to widen the number of shareholders through employee share participation and making taxation of dividends progressive. There are endless other possibilities to allow workers get their fair share of the cake. The US is least likely to lead the way.

  21. @DOD,ah David do regal us with more absolute complete total nonsense bout the ‘irish’ connection and Ukraine from eh 1730.
    Any texts from your ahem alter ego ‘blind’ something or another?
    Do you have a comment or some input as usual no,oh the name calling is rather childish but an improvement on your homophobic comments that other commentators get ‘a room’.

  22. sometimes…..
    “After the fall of the Berlin Wall and the transformation of the SED into the Party of Democratic Socialism (PDS), Wagenknecht was elected to the new party’s National Committee in 1991. She also joined the PDS’s Communist Platform, an orthodox Marxist faction.[3]”

    “Wagenknecht has argued that the Left Party must pursue radical and anticapitalist goals, thereby remaining distinct from the more moderate Social Democratic Party (SPD) and Green Party. She has criticized the Left Party’s participation in coalition governments, especially the Berlin state government, which has made cuts to social spending and privatized some services.[6]
    She has expressed strong support for the rise of left-wing leaders in Latin America, such as Hugo Chávez.[7] She serves as a spokesperson for the Venezuela Avanza solidarity network, and she is an alternate on the European Parliament’s delegation for relations with Mercosur.[4]”
    http://en.wikipedia.org/wiki/Sahra_Wagenknecht

  23. @ JG

    Can you lay off the leprechaunery and stick to what you do really well ?

    “gosh what a s**thole cant even watch a movie nominated for best picture,sounds like Ireland in the 50’s”

    Here’s Orson Welles for ya

    “Look, I love Ireland, I love Irish literature, I love everything they do. But the Irish Americans have invented an imitation Ireland which is unspeakable. The wearin’ o’ the green. Oh my God! To vomit!”
    And when Irish people go to America, they become “a new and terrible race, which is called Irish Americans”

  24. @seafoid have you read the finfacts link yet,like really commenting on the US from that place about supposed ‘controversies’ when you cant stay current with only like one the most popular movies last year,because its ‘banned’

    “Last month a new paper by Barry Z. Cynamon and Steven M. Fazzari, economists working with the Federal Reserve Bank of St. Louis and the Weidenbaum Center on the Economy, Government and Public Policy at Washington University in St. Louis..”

    Cynamon is a visiting scholar at the fed,fazzari would be surprised to hear that hes ‘working’ with the fed…
    No one takes perkins seriously,his comments were ignored as they should have been except in Kula Lumpa.

  25. My impression of Thomas Pickettys argument is that we need to start taxing corporations and the UBER rich at the international level to tackle inequality..who could possibly dispute this ?

  26. for those interested in the topic of ‘income inequality’ in the states this is highly recommended.
    http://equitablegrowth.org/blog

    i find it a bit ‘rich’ getting lectures from someone who supports this…

    “A Malaysian court has sentenced the opposition leader Anwar Ibrahim to five years in jail on sodomy charges, overturning an earlier acquittal and ending his hopes of contesting a local election this month.

    The court said Anwar could remain free on bail while he appeals against the verdict to the country’s highest court.

    Anwar, 66, is the most potent threat to the government of the prime minister, Najib Razak, whose popular support has weakened over the past two elections.

    Sodomy is a crime in Malaysia, punishable by up to 20 years in jail.

    Human rights groups criticised the verdict, calling the legal moves against Anwar politically motivated.”
    http://www.theguardian.com/world/2014/mar/07/malaysian-opposition-leader-anwar-ibrahim-sodomy-jailed-five-years

  27. @ John

    Malaysia is a pretty interesting middle income country, with huge intertwined ethnic / religious / social conflict potential.

    Malay, Chinese, Western (“White elites”), etc

    Politics is sometimes played out by incarcerating the opposition leader on sodomy charges

    The government provides certain investment funds to “poor” Malay only, with some practically guaranteed growth of 8%, pretty interesting construct. Their currency I would describe as a loose peg to the Singapore Dollar.

    They still have a solid population growth rate of 1.5%, enough space, at least a factor of 2 more to grow in GDP per capita.

    Having dinner with a “simple” semiconductor engineer, you can learn a lot about time / spatial real estate development models, with numbers. Boah!

    It would make a von Thünen happy and simply outclasses idiots like Krugman, who I read on that topic also.

    And what can be shown on public TV or cinemas, differs a lot between countries. That the US does have much less of a problem with violence and certain coarse language, does not make it the reference point for the world.

    But it was also fascinating to me to watch certain Leni Riefenstahl movies on public broadcasting in the US, which were forbidden in my home country Germany.

  28. Rf,
    Apart from minor details such as who “we” are,
    What the rate would be, where the revenue would go & who the corporations & über rich are, nobody could disagree with you .

  29. D O D,

    your Sahra Wagenknecht as “decent German citizen-serf” made me smile.

    She is the leader of the Communist platform, goes to bed with Oscar Lafontaine, former German SPD finance minister, physicist and has of course an agenda, and …..

    a PhD in economics !

    interesting topic: “The Limits of Choice: Saving Decisions and Basic Needs in Developed Countries”

    I am going to read her thesis, but since I have to many books, I was trying to read in in the local university library first, but they have it only online on a pay per view basis. Hääh?

    @ John

    I would not over dramatize Wagenknechts statement to international things like Chavez. A lot of this is internationalist folklore, for German internal consumption, and many people love to listen to “el commandante Che Guevara” (short term central bank chief or finance minister, I believe), who would not touch his economic policies with a nine foot pole.

    She previously tried to frame her party as the true heirs to “social market economy” a la Erhardt.

    The combination is probably somewhat difficult to understand for non-Germans, but I believe to understand that to a certain degree, with respect to longer term party strategy / positioning views.

  30. RF,
    In other words don’t confront my top of the head, Cabernet fuelled suggestion with reality . BTW if International Rescue were to oppose an oligarch tax how much would the Irish exchequer get.

  31. @francis the states has some problems sure,but first amendment rights aren’t one them.Perhaps our man in KL would give us his opinion on the jailing off the opposition leader for sodomy, or the banning of ‘Wolf” that is if he’s allowed!

    @MH..’Sears and JC Penney, retailers whose wares are aimed squarely at middle-class Americans, are both in dire straits.”

    JCP is having problems for exactly the opp. reason the decision by Johnson to all but abandon its core market and go upmarket.

    “A strategic mistake made close to two years ago, regarding its pricing strategy –replacement of sales through coupons with everyday low prices.

    The old policy has been working well for retailers, because it hypes consumer emotions, making them feel smart and encouraging them to talk with other consumers about it. That’s how hype and buzz begins.

    JC Penney did away with this strategy after Ron Johnson assumed the helm of the company, modeling the company’s stores after those of Apple”

    http://www.forbes.com/sites/panosmourdoukoutas/2013/09/27/a-strategic-mistake-that-haunts-j-c-penney/

    Sears is getting asset striped like Ireland by Eddie.

    http://www.salon.com/2013/12/10/ayn_rand_loving_ceo_destroys_his_empire_partner/

    But difficult to know that what with being so far away and state censorship,no reason for a few facts to stand in the way of a good rant against the US,hows that gini coefficient looking over there these days ?

  32. Tull – it’s not my suggestion, as per the comment it’s thomas pickettys. Now I havent read his book yet so cant comment on the suggestion in depth, but I thought it an interesting line to begin with and was hoping those with something meaningful to say and a deep knowledge of the economics and politics of this plan might weigh in with an analysis and how it might be implemented in practices.

    NOW I AGREE that defining ‘we’..’working out the rate’..’defining the rich’..’making a plan as to where the revenue would go’.. are all important questions. I dont think the existence of these questions negates the general premise, though YMMV.

    But this is a technical issue demanding a technical reponse and I am not an economist.

  33. @rf

    David Madden introduced the review of Piketty [well worth reading as the book is ~1000 pages – but I did comment quite a bit and provided a few illustrative snippets.

    Thread here: http://www.irisheconomy.ie/index.php/2014/01/22/inequality/

    @Malaysia

    In solidarity

    @Sahra Wagenknecht

    Pls ignore the ‘gurrier elements’ on this blog. Keep up the good work.

    @The Gurriers mit dobbel Fig Leaf

    .

  34. @francis,not familiar with Lenis work but intrigued,growing up these films were banned,making sure all teenagers in a ireland watched them,Life of Brian,Meaning of Life,Clockwork Orange.
    I thought the Oscars were well deserved overall,Apples tax work/planning is impressive,doesn’t reconcile with birkin wearing Cali surfers.Are Germans irrated by it at all,with the Russian Bear growling again,can we expect German capital in NY.
    You may be interested in the bits regarding the financial crisis.
    http://en.wikipedia.org/wiki/Censorship_in_the_Republic_of_Ireland#Film_censorship

  35. @ DOCM

    The subject is corporation tax, not inequity between income groups…

    So it is and the challenge is to replace 3% of GDP in the OECD area with a new tax as health expenditures rise in ageing societies.

    Your dividend proposal wouldn’t work.

    High growth companies are not dependable payers of dividends.

    Warren Buffett’s Berkshire Hathaway’s overall book gain 1964-2013 is 693,518% but he hasn’t paid out a dime in dividends.

    Apple shareholders received their first dividends in 17 years in 2012. Microsoft paid its first dividend in 2003, 17 years after going public.

    Not every group of workers could make €1 billion tax-free as Eircom workers did as the golden goose passed through five owners.

    A small number of non-trading shares in private companies wouldn’t be much use.

    There are not ‘endless possibilities’ in a practical sense. Tax systems are rarely subject to significant change.

    As flawed as the current system is, at least most of the cost falls on capital rather than labour.

    @ john gallaher

    John,

    I’m not going to comment on internal political issues. I like living here and that’s one of the conditions of my long-term visa.

    To make a general point about the evolution of democracy in Asia and elsewhere, it is a long process.

    In your own neck of the woods, next November will be the 100th anniversary of the first direct elections to the US Senate.

    The noble goal was to end the control of most US Senate seats by business interests via votes in state legislatures.

    Most political bribery in the US has been legalised since then and the current US Supreme Court lifted a 1907 ban on corporations directly funding politics.

    In 2009, Senator Dick Durbin of Illinois said in a radio interview in Chicago: “Hard to believe in a time when we are facing a banking crisis, that many of the banks created, that the banks are still the most powerful lobby on Capitol Hill. They frankly own the place.“

  36. “Tax systems are rarely subject to significant change.”

    I dunno about that, Michael. Personal tax rates in the US post WW2 have been like the grand old duke of York . When they were up they were very up and now that they are down they are very down.

    The neolib model is based on low tax and low interest rates and now it’s banjaxed. Great “value” there generated by bringing tax and interest rates down but as Bill Gross will tell you it’s not clear where we go from here.

  37. @ seafóid

    I’m referring to the structure or tax heads as they are called.

    It’s rare for an existing tax that raises significant funds to be dropped and substituted with a new one as politicians fear antagonising voters.

  38. @ MH

    Buffet’s company is the most atypical one that you could have mentioned and the other two are not far behind.

    The Wiki on the first;

    “Berkshire’s class A shares sold for $165,265 as of February 3, 2014, making them the highest-priced shares on the New York Stock Exchange, in part because they have never had a stock split and have only paid a dividend once since Warren Buffett took over, retaining corporate earnings on its balance sheet in a manner that is impermissible for private investors and mutual funds. Shares closed over $100,000 for the first time on October 23, 2006. Despite its size, Berkshire has not been included in broad stock market indices such as the S&P 500 due to the lack of liquidity in its shares; however, following a 50-to-1 split of Berkshire’s class B shares in January 2010, and Berkshire’s announcement that it would acquire the Burlington Northern Santa Fe Corporation, parent of BNSF Railway, Berkshire replaced BNSF in the S&P 500 on February 16, 2010.”

    I have no doubt that the beneficiaries of the Eircom ESOP would not mind if similar good fortune could be the lot of other workers.

    The bottom line is that most companies from the smallest to the largest and in all countries (with the probable exceptions of Cuba and North Korea) are organised as limited liability companies and the real question is how they can be controlled so that all involved in them can benefit in an equitable manner i.e. in accordance with their contribution. Getting speculative financial parasites off their backs would also help.

  39. @Michael Hennigan

    You may (or may not, lets cover the bases) be interested in something from Mariana Mazzuacto./

    She argues that SMEs (and entrepreneurs in general) are not good targets for state support, at least in the UK and US. What SME’s most do is fail.

    http://www.economist.com/blogs/schumpeter/2014/02/invitation-mariana-mazzucato

    Interesting to Fyffes “merging” with Chiquita. The new company will be tax domiciled in Ireland. We are not a tax haven mind you.

  40. @me

    What SME’s most do is fail.

    The apostrophe defeats my attempts at seriousness once again.

  41. Oirish Americans

    The fighting Irish. No Sheila we do not have to conform to the stereotype.

    articles.chicagotribune.com/2014-03-09/news/sns-rt-us-usa-massachusetts-arrests-20140308_1_police-arrest-day-party-massachusetts

  42. @ Shay Begorrah

    I’m in agreement with much of what Mariana Mazzucato says.

    There is a high startup failure rate and this is why the Irish Innovation Taskforce jobs targets in 2010 of up to 215,000 new tech jobs were so fanciful as a huge number of new firm creations were needed.

    US research shows that surviving startups do have an impact as do new high growth firms.

    It’s easier to be young and grow in the US than in Europe.

    Mazzucato considers it “a travesty of justice that a company that owes so much to public investment devotes so much energy to reducing its tax burden by shifting its money offshore and assigning its intellectual property to low-tax jurisdictions such as Ireland.”

  43. It would be great if companies assigned their intellectual property to Ireland. But they do not.

    Patent royalty flows in the 2012 BOP:

    Inflows: €3.7 billion
    Outflows: €32.0 billion

  44. One of the things about those Italian SME collapses is that German unemployment has fallen consistently since 2011. The 2 wouldn’t possibly be connected, would they ?

  45. @seafóid

    One of the things about those Italian SME collapses is that German unemployment has fallen consistently since 2011. The 2 wouldn’t possibly be connected, would they ?

    Are you trying to say that just because two thirds of EU trade is internal and countries can not devalue a race to the bottom in wages will unleash deflationary pressures and reduce total employment as demand inevitably drops?

    Ridiculous.

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