In that case a clearer position emerges that lets us resolve the “extreme” (and legally unjustifiable) position of neoliberalism that says that tax must be avoided and the relativist position that says all charges must be accepted. This summarised in the concept of tax compliance. Tax compliance is seeking to pay the right amount of tax (but no more) in the right place at the right time where right means that the economic substance of the transactions undertaken coincides with the place and form in which they are reported for taxation purposes. This needs a little explanation.
First, the right amount of tax means that the law is properly applied and that the choices available in law are honoured. This means a company can quite legitimately argue with a tax charge it thinks is improperly imposed.
Second, the right place means that tax is due in the country where the economic substance of a transaction arises.
So let us take this as true.
In the Vodafone case the economic substance of the transactions was in Germany. They were and are, after all, flogging phones and air time to Germans. In Germany. By charging UK tax on this it would appear that Vodafone has overpaid tax to the sum of £1.25 billion.
Lady Green is a non-British citizen living in a non-British jurisdiction. The economic substance of her income is therefore nothing whatsoever to do with the UK or Britain. Just as the economic substance of a US based shareholder receiving dividends from BP, or a Russian one receiving such from a UK based company is nothing to do with the UK or the UK taxman.
Excellent, so, we\’ve got it straight from Ritchie\’s mouth that UKuncut are are simply deluded. Both Vodafone and Lady Green are entirely tax compliant. Indeed, Vodafone is being oppressed by the UK taxman.
And isn\’t that interesting?