As I\’ve been saying for some time now

The exclusion for warehouses, such as Amazon\’s eight distribution centres, is contained in the double taxation treaty the UK negotiated with Luxembourg in 1966. is registered to a Luxembourg company, Amazon Europe Holding Technologies SCS, and the site runs off the group\’s servers in Ireland.

And that is indeed the standard OECD double taxation treaty.

The Guardian\’s investigation into the rules on permanent establishment involved looking at HMRC manuals, international double taxation treaties dating back to the 1960s, and guidelines for tax treatments of multinational businesses set out by the Organisation for Economic Co-operation and Development.

Of course, they could have just read this blog…..

7 thoughts on “As I\’ve been saying for some time now”

  1. Even the BBC is starting to get it. Both Wake Up To Money and Today both commented that it was the rules that were the issue and not the companies applying them.

    Shame it’s taken so long and the narrative is so embedded that this wont make a sh1t of difference to the general public.

  2. I love that.

    “Our investigation into taxation has involved finally getting round to actually reading the rules”

  3. Fething hell – that didn’t even have any special characters in it.

    Somethings obviously gone wrong, either with your site coding or the blog software.

  4. The Graun, if not Ritchie or its more excitable commentators, has focused on the rules for a while.

    And in this context, the rule *is* clearly obsolete.

    In 1966, the concept that you could operate a retail business in a country whilst your establishment in that country consisted solely of warehouses and an admin office would have been completely, insanely incomprehensible. Now, it’s SOP.

    There is absolutely no way that if the rules were being drawn up today, they would have been drawn up in a way that exempted Amazon from counting as established in the UK.

    On the other hand, the point’s largely academic, since Amazon doesn’t make any money anywhere, as highlighted by another good Graun piece that gets it.

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