Ritchie headlines we can answer

Has the US declared tax war on Europe?


More here:

US Treasury Complains Over EU Tax Probe Into Apple – JP Morgan Entirely Wrong About $19 Billion Bill

7 thoughts on “Ritchie headlines we can answer”

  1. No, but they’ve declared tax war on anyone living overseas with US citizenship, irrespective of whether they’ve ever even been to the US…

    But Ritchie is in favour of that.

  2. The real issue isn’t revisiting deals agreed on tax rates. As noted, not much money is really at stake if they claw back the difference between the “special” deal and the general rate.

    It’s what they are trying to do with the transfer pricing calculations. Reading between the lines, they are trying to revisit the pricing of intellectual property supplies to subs in Ireland. That could be pretty significant.


  3. “In Starbucks, the Commission not only rejected the Member State and taxpayer’s
    agreement to use the TNMM, but also decided that the comparable uncontrolled price (“CUP”)
    method should have been used because purportedly reliable comparable transactions were
    available. According to the Commission’s analysis, no (zero) royalty should be treated as
    having been paid by the relevant Starbucks entity, which it believes did not derive any benefit
    from intellectual property related to proprietary roasting activities. Although we do not have
    enough information to evaluate how the OECD TP Guidelines would apply to the facts of the
    Starbucks case, the Commission’s application of its version of the arm’s length principle seems
    to result in an allocation of significant profits, which are likely related to intellectual property, to
    an entity that does not appear to own or develop any intellectual property and that operates in a
    limited risk capacity. While its decision discusses Member State law and the OECD TP
    Guidelines, the Commission states that its reasoning is based on neither of those but instead on
    the TFEU’s general principle of equal treatment in taxation. But the U.S. Treasury Department
    is aware of no guidance from the Commission on how the TFEU’s general principle of equal
    treatment would apply to allocate value from intellectual property, one of the most difficult and
    complex areas of transfer pricing.”

    They are after the IP value.

  4. He is amazing about the US’ refusal to sign up to one of his “morally approved” projects just now

  5. If it would make Ritchie feel better, I personally could declare war on Europe.
    I don’t have any troops, so I can devote 100% of them to the attack.
    I, personally, will be too busy forgetting about the whole thing to participate.

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