Is Zero-10 under threat?

[Manximus Aururaneus]

15 minutes ago, GD4ELI said:

Grow up. The EU obliged Ireland to recover 13 billion euro from Apple, similar situation with Belgium and some multinationals. Luxembourg is under severe pressure from Brussels. Don't confuse the EU with your own tinpot administration.

 

Of course, Cornwall and Isles of Scilly, being NUTS2 areas qualify as ‘a’ areas under the RAG on grounds of having a GDP per capita of less than 75% of the EU average qualify for Tier 2 EU regional grants (they did quite well out of Tier 1 too as I recall) - so it wouldn't do for you to go upsetting your political (and financial) masters would it? After all 'tinpot' is better than 'no pot' when you need to spend a P or two 

 

[Andy Onchan]

Just now, Manximus Aururaneus said:

 

Of course, Cornwall and Isles of Scilly, being NUTS2 areas qualify as ‘a’ areas under the RAG on grounds of having a GDP per capita of less than 75% of the EU average qualify for Tier 2 EU regional grants (they did quite well out of Tier 1 too as I recall) - so it wouldn't do for you to go upsetting your political (and financial) masters would it? After all 'tinpot' is better than 'no pot' when you need to spend a P or two 

 

And guess what? Cornwall was in favour of Brexit (56.5/43.5) as well.

[P.K.]

16 minutes ago, Andy Onchan said:

And guess what? Cornwall was in favour of Brexit (56.5/43.5) as well.

Because they had been assured by Farage, Gove and Johnson that the UK would continue to maintain the EU grants they were getting.

Strange but true it turned out to be a load of BS.

[Andy Onchan]

5 minutes ago, P.K. said:

Because they had been assured by Farage, Gove and Johnson that the UK would continue to maintain the EU grants they were getting.

Strange but true it turned out to be a load of BS.

Let's wait and see, shall we?

Can you not see the irony in all of this??

[Manximus Aururaneus]

26 minutes ago, Andy Onchan said:

And guess what? Cornwall was in favour of Brexit (56.5/43.5) as well.

Correct, Mebyon Kernow are more concerned about DevonWall.

[twinkle]

46 minutes ago, Andy Onchan said:

And Ireland has told them to get stuffed. The issue at stake here is whether the Commission has the legal right to determine what a member states tax regime should be.

The ruling by the General Court of EU will be a milestone in EU taxation affairs. If it goes against Ireland/Apple then Ireland won't see a penny of it but it will open the gates for The Commission to start setting tax rates that it, and it alone, thinks should be set. 

It's not going to end well, either for Ireland or the other members.

they are now attempting to change the EUSSR tax laws for ALL  their countries, well good luck paddy's, without your 12.5% tax rate you are fucked!!!!, as are other LOW TAX jurisdictions,there will be no deviation, you shall ALL do as you're told.

http://en.euabc.com/word/897

http://www.debatingeurope.eu/2013/09/10/should-tax-rates-in-the-eu-be-harmonised/#.Wip48GdLE5s

[piebaps]

From the EU report

"the Council has also agreed that the absenceof a corporate tax or applying a nominal corporate tax rate equal to zero or almost zero cannotalone be a reason for concluding that a jurisdiction does not meet the requirements"

http://www.consilium.europa.eu/register/en/content/out?RESULTSET=1&DOC_TITLE=business taxation&DOC_SUBTYPE="REPORT"&i=COCGRTTC&ROWSPP=25&ORDERBY=DOC_DATE DESC&DOC_LANCD=EN&typ=SET&NRROWS=500&TARGET_YEAR=2017

 

Phil Craine talking through his arse (again). BEPS is an issue but IOM signed up to the BEPS intiative in 2016. https://www.gov.im/categories/tax-vat-and-your-money/income-tax-and-national-insurance/international-agreements/base-erosion-and-profit-shifting/

 

And as for Solly, well if he hadn't brought forward the Tax Exempt Company regime in 1984 while he was in charge of the tax system, we wouldn't have to whore ourselves to the CSP industry.

[P.K.]

29 minutes ago, Andy Onchan said:

Let's wait and see, shall we?

Can you not see the irony in all of this??

Absolutely.

Just how thick are some folks?

I mean, believing Farage, Gove and Johnson.

Laughable...!

[Manximus Aururaneus]

9 minutes ago, P.K. said:

Absolutely.

Just how thick are some folks?

I mean, believing Farage, Gove and Johnson.

Laughable...!

The Regional Assistance Grant Scheme (Tier 2) extends up to 2020.

Last nights agreements states; 

So what Farage, Gove and Johnson stated ( and Theresa May confirmed in her Lancaster House speech) is irrelevant - the UK remains in the theme until it ends anyway.

• Britain remains part of the European Development Fund until it expires.

[thesultanofsheight]

1 hour ago, piebaps said:

From the EU report

"the Council has also agreed that the absenceof a corporate tax or applying a nominal corporate tax rate equal to zero or almost zero cannotalone be a reason for concluding that a jurisdiction does not meet the requirements"

http://www.consilium.europa.eu/register/en/content/out?RESULTSET=1&DOC_TITLE=business taxation&DOC_SUBTYPE="REPORT"&i=COCGRTTC&ROWSPP=25&ORDERBY=DOC_DATE DESC&DOC_LANCD=EN&typ=SET&NRROWS=500&TARGET_YEAR=2017

 

Phil Craine talking through his arse (again). BEPS is an issue but IOM signed up to the BEPS intiative in 2016. https://www.gov.im/categories/tax-vat-and-your-money/income-tax-and-national-insurance/international-agreements/base-erosion-and-profit-shifting/

 

And as for Solly, well if he hadn't brought forward the Tax Exempt Company regime in 1984 while he was in charge of the tax system, we wouldn't have to whore ourselves to the CSP industry.

As I said above the shift is inevitable and the flaws with zero ten are apparent and effectively created a race to the bottom once the EU forced us to do away with the attribution regime in 2012 which essentially made Manx tax avoidance legal for Manx residents using Manx companies and took even more tax out of the system. As you say we’re already committed to BEPS anyway and other jurisdictions have started to migrate away from just managing companies that lack any real substance. That should be good for us longer term - real companies that do real things like real trading that need real staff working for them rather than being administered by CSPs. As for Solly he was right in what he said in the papers the other week. Yes he was the Godfather of the Manx CSP and exempt insurance company sectors but there is no denying that it created mass employment and brought a lot of businesses to the IOM for a long time. Jersey brought it in before us if I remember correctly anyway so we were forced to follow. It’s been on a timeline now for 10 years but, again, as usual nobody in government is coming up with any viable alternative. 

[Andy Onchan]

38 minutes ago, P.K. said:

Absolutely.

Just how thick are some folks?

I mean, believing Farage, Gove and Johnson.

Laughable...!

The EU is knackered.... guess who's reducing their corporate tax rate in 2018 from 33.99% to 29% and then down even further to 25% in 2020?  And For SME's 20% from 2018 on the first €100.000 profit.?  Belgium. Is that fair on their close neighbours, like Germany and France who have higher rates of corporate tax?

That's what I mean about irony. 

[P.K.]

47 minutes ago, Manximus Aururaneus said:

The Regional Assistance Grant Scheme (Tier 2) extends up to 2020.

Last nights agreements states; 

So what Farage, Gove and Johnson stated ( and Theresa May confirmed in her Lancaster House speech) is irrelevant - the UK remains in the theme until it ends anyway.

• Britain remains part of the European Development Fund until it expires.

Is it "Last nights agreement" as in yet to be ratified by all the EU states?

Wait and see mode. Because I suspect all the "Hard Brexit or No Brexit" wing of the tory party will have something to say about it.

[GD4ELI]

2 hours ago, Andy Onchan said:

And Ireland has told them to get stuffed. The issue at stake here is whether the Commission has the legal right to determine what a member states tax regime should be.

The ruling by the General Court of EU will be a milestone in EU taxation affairs. If it goes against Ireland/Apple then Ireland won't see a penny of it but it will open the gates for The Commission to start setting tax rates that it, and it alone, thinks should be set. 

It's not going to end well, either for Ireland or the other members.

The Irish government has reached an agreement with Apple to start collecting the €13bn ($15bn) owed by the tech giant.

https://www.theguardian.com/technology/2017/dec/05/ireland-reaches-deal-with-apple-to-collect-13bn-in-back-taxes

[Phillip Dearden]

23 minutes ago, thesultanofsheight said:

As I said above the shift is inevitable and the flaws with zero ten are apparent and effectively created a race to the bottom once the EU forced us to do away with the attribution regime in 2012 which essentially made Manx tax avoidance legal for Manx residents using Manx companies and took even more tax out of the system. As you say we’re already committed to BEPS anyway and other jurisdictions have started to migrate away from just managing companies that lack any real substance. That should be good for us longer term - real companies that do real things like real trading that need real staff working for them rather than being administered by CSPs. As for Solly he was right in what he said in the papers the other week. Yes he was the Godfather of the Manx CSP and exempt insurance company sectors but there is no denying that it created mass employment and brought a lot of businesses to the IOM for a long time. Jersey brought it in before us if I remember correctly anyway so we were forced to follow. It’s been on a timeline now for 10 years but, again, as usual nobody in government is coming up with any viable alternative. 

This is all quite sensitive.

It is hard to say that IOM taxpayers using companies are engaging in avoidance. Avoidance is frustrating the will of Tynwald - in this case Tynwald has said "have a 0% rate" and shareholders have lapped it up. [But I see where you are coming from].

If you accept that gaming and fiduciaries are "Finance Sector" then this sector is about 70% of the economy (some will argue with definitions but it's still big) and much of the rest is supporting those sectors. This means they are fundamental to our economy.

In the short-run, assessing how this pans out will be very important for the Island. "Substance" is quite a nebulous term and how it is defined will matter. Even the banks, Life Companies, Captives and Fund Managers will be concerned as whilst they do have a substantial presence here, much of what comprises their business (debtors, lenders, risks, policy-holders etc...) are elsewhere. The argument about substance is strongly correlated with the rate of tax discussion - we have a number of businesses here that would not be here if they had to bear an increased tax rate - by their nature the ones with little substance here can move easily (or they may cease to trade).

I expect a compromise will be achieved which will allow the economy to continue but either with some restriction on what can be done or more regulatory hoops to jump through. In the longer run, we should learn how brave it is to continue with so much of our economy dependent on one feature of our tax system and start, quite quickly, to develop strands to our economy that do not depend on our tax position.

As an aside, no-one really invented Exempt or zero-tax companies. IOM law used to emulate UK law and allowed company residence to be determined by management and control ie where it was managed. The IOM "formalised" this regime to make it easier to manage (directors on IOM) and more profitable (Exempt Co Fees). When the Code of conduct Group frowned on Exempt companies we moved to two "fudges" (ARI and DPC) that worked for a while but after further EU pressure  "zero-tax" (with its variants) was the inevitable result. From an outside point of view, the names have changed but these are all zero-tax companies. We bitch about the details but from an outside viewpoint (customers and regulatory authorities) it is the substance rather than the labels which matters.   

As a further aside, the De Beers case of 1906 determined that the real business of a company is carried on where it highest level of control is exercised. If this was persuasive we would not have a big problem (some may need to tighten up processes)...but I am not banking on it.

 

[Andy Onchan]

15 minutes ago, GD4ELI said:

The Irish government has reached an agreement with Apple to start collecting the €13bn ($15bn) owed by the tech giant.

https://www.theguardian.com/technology/2017/dec/05/ireland-reaches-deal-with-apple-to-collect-13bn-in-back-taxes

The Irish government must now put the sums in a blocked bank account while waiting for the result of Apple’s and its own appeal to the European Commission.