No Times, just no

The permanent establishment rules have been ripe for exploitation, especially by technology companies, which are able to shuffle intellectual property and lucrative royalty fees around the world.

Google, for instance, argues that its London headquarters do not have a taxable presence in Britain — even though the search giant employs about 4,000 people in the capital. This definition enables it to funnel profits derived from UK-based clients legally through its headquarters in Dublin to a Caribbean tax haven.

That is not the argument. Instead, it is that Google UK does have a permanent establishment in the UK. But that Google Eire does not. And Google Eire is the one doing the selling of advertising, not Google UK.

Further, it does not funnel profits, it charges the ad revenue from Ireland.


3 thoughts on “No Times, just no”

  1. It’s just confusion about the corporate veil.

    Google, considered as a group, clearly has a UK PE. But when you consider it as individual companies. Google UK clearly has a UK PE, but Google US doesn’t.

    So Google (US) can say that legally it doesn’t have a UK PE, even though Google Group actually does. This is clearly absurd and can only result of flagrant abuse… unless you pay attention to what you’re talking about.

    Apropos of nothing, I have a number of relatives in France – in fact, many of the cousins are French. As a result, my extended family owns a lot of property in France, and taken as a whole we generate a lot of our income there. And yet I don’t even file a return in France, much less pay tax there!

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