Ritchie headlines we can answerAugust 25, 2016 Tim WorstallRagging on Ritchie7 CommentsHas the US declared tax war on Europe? No. More here: US Treasury Complains Over EU Tax Probe Into Apple – JP Morgan Entirely Wrong About $19 Billion Bill previousSo, just done Radio Sputnik againnextRitchie and the blockchain 7 thoughts on “Ritchie headlines we can answer” abacab August 25, 2016 at 12:00 pm 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. Agammamon August 25, 2016 at 3:49 pm The US has declared tax war . . . on Americans. jono August 25, 2016 at 4:28 pm 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. https://www.treasury.gov/resource-center/tax-policy/treaties/Documents/White-Paper-State-Aid.pdf jono August 25, 2016 at 4:42 pm “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. Flatcap Army August 25, 2016 at 5:18 pm He is amazing about the US’ refusal to sign up to one of his “morally approved” projects just now CayleyGraph August 25, 2016 at 7:20 pm 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. Diogenes August 25, 2016 at 8:25 pm Is it possible that today we have reached Peak Murphy? Leave a Reply Cancel replyYour email address will not be published. Required fields are marked *Comment Name * Email * Website Save my name, email, and website in this browser for the next time I comment.