Odd that you missed off the fact that Chuka Umunna also laid the blame for the Barclays tax situation firmly at the door of the former Labour government and the tax laws it wrote.

Odd that you think I would absolve Labour of blame for being too nice to tax dodgers.

What is truly gorgeous about this is the following:

1) Barclays sold a subsidiary that year, booking a £6 billionish profit on having done so. There is no tax to pay on profits made from selling a subsidiary: as with The Guardian’s selling of Autotrader the year before.

Don’t forget, R. Murphy (and Richard Brooks as well) said that The Guardian was entirely tax compliant, absolutely doing what Parliament wanted, when they did this.

2) Barclays had previous losses which it could use to offset against profits that year, As, of course, The Guardian does each and every year: they make a profit on some parts of the business, lose money on The Guardian, and the two are netted off to give the tax bill.

So once again UKUncut goes haring off after someone who is, for the most part, doing exactly what everyone wants them to be doing, Paying the right amount of tax on the profits they make.

– it was good to see the Police having a word with the angry middle manager of Barclays.

After all, the protestors are campaigning to protect, amongst other things, the wages and resources of the Police, whereas Barclays are doing their best to avoid contributing to any Police costs.

that’s not comparing UK corporation tax against global profits is it?

Tim, the more I read Richard Murphy & brooks the more I get confused at their arguments.

Both say avoidance bad, yet Barclays & guardian did nothing wrong in the past, yet happily Murphy says the opposite yesterday on BBC breakfast & his blog.

The argument is flawed on tax avoidance & dealing with it.

The protests against tax avoidance are equally removed from average joe’s struggles to keep job & pay bills along with council cuts. How are they dealing with THESE issues?

Tim Worstall – why do I have to keep educating you?

1) GMG didn’t have to pay tax on the autotrader deal with the profits were re-invested, which is different to offsetting profits against previous losses. Not sure how that invalidates UKuncut’s arguments though.

2) Inter-departmental cross-subsidising is different to offsetting between different financial years. I suspect you know this, but are being deliberately obtuse in the hope no one will spot this.

, Paying the right amount of tax on the profits they make.

No – its tax avoidance and its bad practice, hurts the economy and makes us all worse off.

I’m happy to once again link you to the post I did earlier on the subject.

UKcuts The protests against tax avoidance are equally removed from average joe’s struggles to keep job & pay bills along with council cuts.

Erm, really? You don’t perhaps think the cuts are worse because of massive corporate tax avoidance?

Sunny,

I’n confused. Are you classifying offsetting profits against previous bad practice, tax avoidance? That’s absolutely standard and is done by every company in the country.

@7 Sunny

How much tax was ‘avoided’ in 2009/10, and how big is the deficit for the same period?

The amount claimed to be avoided by the likes of Richard Murphy & Richard Brooks dont come anywhere near the figure of the deficit. Last figure I read was approx £40bn avoided against a deficit of £160bn odd

So when you’ve exhausted that avenue, how are the likes of these tax experts and their followers suggesting the remaining gap in finances is filled?

I’m firmly in the cuts are need, but are being done too deep & fast camp. The gov should be cutting one area, letting the impact hit, before addressing another area.

Avoidance is simply a side show IMO that’s wasting an opportunity for real protests. I dont call a few weekender protesters forcing stores to close a working form of protest. Only sustained continuous protests will achieve anything IMO.

These firms arent breaking laws, only morals so nothing is going to happen. UK Uncut will still be fighting the same arguments and still getting nowhere in doing so this time next year. By then thousands will be jobless, libraries and surestarts closed, tuition fees ramped up along with our taxes.

IMO no1 priority is tackling the cuts. Avoidance can be addressed once the seed is planted and public fully on side with protesting. IMO people cant and wont relate to students closing stores. They’ll go the other way and feel unable to relate to any protest forms out there.

Read some of the action reports on the uncut site if you need proof of alienation.

What really bores me about the GMG tax avoidance argument is that it’s made by people – like Tim Worstall – who couldn’t give two shits about tax avoidance. They’re just indulging in a bit of impotent whataboutery.

Tax avoidance = bad

That’s about the sum of it.

As far as Barclays goes, it isn’t *just* about tax – it’s the fact that the company has benefitted from an astronomical taxpayer bail out (as John Varley himself acknowledges), and is still tax avoiding, resisting regulation and paying its staff gargantuan bonuses. All this during the worst spending cuts in British history thanks to a crisis caused by the reckless behaviour of the banks.

Of course us Barclays customers can always do our banking online resulting in counter staff being laid off due to the UKucunts terrorist activities.
I’m sure that’s what they actually want to achieve, more people out of work.
Right on Brothers and Sisters!!

@10 Ellie

What about all the non UK banks whom the banks tax won’t affect them as they don’t have to pay it, or most of our other taxes either?

Tax avoidance by corps is tiny compared to individuals who owe some 6x that of corps I keep reading when the avoidance line is dragged out.

It’s an ideological stance that doesn’t begin to address the issue of cuts.

Same questions/points I put to Sunny in 9 I also put to you. Ideology is why these cuts are happening so fast & so deep. You can’t fight ideology with more ideology.

Luis – how is being allowed to offset last year’s losses with this year’s profits to minimise tax liabilities a good practice? genuine question. What’s the rationale?

Sunny,

I’m not sure I know the answer, all I know is that it is standard practice (link to HMRC) and if you don’t like it, criticize the law not the companies abiding by it.

I’d be interested to know the rationale too. Here are my guesses:

1. Start-ups, and new projects within existing firms, make operating losses, so allowing losses to be written off against profits encourages investment and entrepreneurial behaviour.
2. Timing is arbitrary. Obviously if you make a loss within an accounting year, you write it off against tax because that loss reduces the profits upon which you pay tax. The same principle is at work moving losses across accounting years. As things stand, there’s no need to worry about when you recognize losses because you can write them off against profits whenever they occur. If the law was changed to introduce an annual cut-off, companies would simply change the timing of when they recognize losses (which is inherently a choice, there is often no ‘natural’ timing of losses) to spread them out across the years.
3. consider a firm that operates in a risky market, such that some years it makes losses and others profits. If its profits averaged out to zero over the years, under the current law it would pay zero tax on profits. If you changed the law to tax profits when they occur and disallow write-off of previous losses, if you look over the span of years this firm would be paying tax yet not making any profit – hence it would be bankrupt.
4. if changing the law on this matter achieved anything (i.e. if firms were unable to choose timing of losses) it would amount to a tax increase. If you want to increase taxes on corporations, it’s not obvious this is the best way to do it, because it hits firms that are obviously fragile having made losses recently. Why not just raise taxes on profits?

I think 3. might be the strongest argument.

[ didn’t somebody (Richard W?) say some of the banks weren’t being allowed to write-off all of the losses made during the crisis? ]

“1) GMG didn’t have to pay tax on the autotrader deal with the profits were re-invested, which is different to offsetting profits against previous losses. Not sure how that invalidates UKuncut’s arguments though.”

And that’s exactly what Barclays did. They took that £6 billion ish and reinvested it in the business. This is one of the things that raised their capital ratios o the new, higher, levels both desired and enforced by law.

You know, this thing that the banks should have more capital so as to make them less fragile?

So, this part of it is exactly the same as the Guardian. There is no corporation tax on the sale of a subsidiary, where the money is then reinvested witin the business. It’s absolutely, exactly, the same.

“how is being allowed to offset last year’s losses with this year’s profits to minimise tax liabilities a good practice? genuine question. What’s the rationale?”

It’s an essential part of any rational tax system.

As I hope you know, profits will bounce around quite a lot. Not just banks, but all sorts of companies, depending upon the economic cycle, will have profits in this or that year, then losses in that or another year. It’s just the nature of the beast that you do.

So, imagine, we’ve two ways of doing this: we can tax a company on its cumulative profits, that is the profits that it makes over the decades, or we can tax it on the profits it makes only in one particular year.

Which is fairer? For example, (and this is close to reality for me), think of a small company that’s about to embark upon a large project. Build a new factory say. For the first few years it’s going to make huge whacking great losses.

Because, out of new equity and loans, it’s spending all this money on the new factory, but it’s not going to prouce anything for the first few years: because it’s still being built.

After, say, 4 years, the factory starts producing and then there are profits.

Now, what is a fair tax system here? You’re making profits so we’ll have a slice? Looking only at yeat 4? Or do we say, hmm, you’ve lost a lot in years 1-3, and we really ought to be taxing the profits from the project as a whole, not just that profit in year 4. Tell you what, we’ll let you offset those loasses in years 1-3 against the profits in 4 and 5…..only when the actual project is making a profit as a whole will we start taxing it.

And that’s why losses can be offset. Because we’re not trying to tax a company just in one year. Think it through for a moment: many industrial projects are really 30-40 year plans. Opening up a new oil field, building a blast furnace, they’re long term projects. It does seem right and just that we tax the project as a whole, rather than just looking at the results of any one 12 month period.

It’s not just companies that get this either: authors of books can spread their income over three years as well. You might get a nice advance when you actually contract to write the book. Then you’ve got a year in which you write it an you earn nothing more. Then it’s published and maybe it sells lots. But you don’t get your royalties until that third year: yes, publishers pay 3 months after the end of the previous year, so 2010 royalties on sales are paid in March 2011.

So the revenue says, hmm, yes, a book is a three year project, you can spread your income from the book over those three years.

Same with companies: that steel mill is a 25 year project. So you can spread your costs and profits over those 25 years. You can move the losses from the years when you set it up into those years when it is set up and making a profit.

“What really bores me about the GMG tax avoidance argument is that it’s made by people – like Tim Worstall – who couldn’t give two shits about tax avoidance. They’re just indulging in a bit of impotent whataboutery.”

It is true that I say that there is no such thing as tax avoidance. There is obeying the law (tax compliance, tax planning, tax avoidance, tax abuse) and there is not obeying the law (tax evasion). There are only those two categories, inside the law and outside it. We also have a method of determining which is which: the law, as decided by the courts.

However, my ire on this particular point is the gross hypocrisy of some of the campaigners.

We’ve had Murphy R writing reports about how income shifting is very naughty, it’s tax abuse and must be stamped out. And we find that Murphy R. was in fact using income shifting in his own business activities.

We’ve the Guardian shouting about how Barclays are very naughty indeed for not paying corporation tax on 6 billion from selling a subsidiary: and yet this is exactly the thing that The Guardian itself did. In fact, the way that tax law is set up at present, neither The Guardian or Barclays *could* have paid tax on this. Gordon Brown specifically set up the system so that you cannot set off a tax loss from selling a subsidiary against corporation tax: and also that you do not pay tax on selling a subsidiary, as long as it’s all reinvested.

You have to go through incredible contortions to be able to get out of this: it really was Ed Balls and Goron Brown who set the system up to do this.

Then we’ve UKuncut and Richard Brooks (who broke the Vodafone story in Private Eye and also, amusingly, defended the Guardian’s actions in The Guardian).

Look at the four cases so far:

1) Vodafone. The claim is that profits made from selling phones in Germany, from German shops, to German customers, should be taxed in the UK because Vodafone is, in the end, a UK company.

2) Boots, now a Swiss company, should be paying taxes in the UK from selling stuff in the UK, though UK shops, to UK peeps. Because tax should be paid where the profits are made, not just where the company resides.

These are incompatible views of course.

3) Arcadia. Arcadia does pay corporation tax in the UK one what it makes from selling stuff from UK shops to UK peeps in the UK. Here the demand is that Lady Green, who is not a UK resident, not domiciled here, should still be paying UK income tax on her income. This is entirely barking. People who get dividends from a UK company, but do not live or are not domiciled in the UK, do not pay UK income tax on those dividends. If some Yank buys a BP share, we don’t charge him UK income tax on that dividend: obviously not, for we rather like foreigners sending money for our companies to use.

4) Barclays: they not only didn’t avoid tax on that 6 billion, they, by law, were forced not to pay tax on it. Just as The Guardian was forced not to pay tax. And the rolling over of tax relief upon losses to offset against future profits is simply such a normal part of any sensible tax system that I cannot see why anyone is complaining about it. Even Murphy R. is left whining about how banks shouldn’t be allowed to do it, even he thinks its a desirable part of the general tax system.

So, that’s my problem, that’s why I’m so vocal about this. All of the actual examples being used by UKuncut are simply horseshit.

Hey, it’s fun to do the teenage demo bit, been there, done that. But that doesn’t change the fact that all of the actual cases you’re singing “Kumbaya” about are simply nonsense.

If it’s through ignorance then pewrhaps I can inform you. If it’s by design (and for some of those feeding you the stories, it absolutely has to be) then I’m out of luck, aren’t I?

Here’s a genuine question. Why can’t campaigners try to understand what they are campaigning about? Why do idiots like Murphy play such a big role? Why is there so much exaggeration and why are so many misleading claims made (in the OP here – you compare taxes paid on UK profits against global profits including asset sales … why do that?). Is it really true that it’s better to have people getting angry and waving placards but holding a set of incoherent and inconsistent beliefs, and that if people somehow stopped to understand what the fuck they were talking about, the “movement” would suffer? I don’t understand – they way I see it, if people had any integrity, they’d respond to some of the points Worstall makes above with something like “ah, yes, some good points there. It doesn’t make much sense to be both angry about Vodafone and about Boots at the same time. Perhaps I ought to reconsider my views”. But they won’t, they’ll just go on the attack and accusing him of defending is corporate overlords.

It’s perfectly possible to get angry and campaign on tax, after understanding things rather than before. It is possible to look at companies that use legal shenanigans to get out of paying tax that we – the democratically elected government – want them to pay, and to get angry about that and seek to change things to shut down loopholes, and to campaign for greater transparency, new legislation, and get angry about tax havens etc. I wholeheartedly support keeping a close eye on corporate tax shenanigans and getting angry about their existence and what to do something about it. I want the government to collect the taxes the system is designed to collect and I don’t like companies using lawyers and accountants to come up with elaborate offshore wheezes to dodge tax (as opposed to simply doing perfectly ordinary things like writing off past losses) and if staging improvised comedy and waving placards gets them to stop doing that, well I’d be surprised but happy.

An advantage of understanding what you are talking about is that you are less likely to try and fix things the fixing of would make things worse. Take Philip Green and is wife and Arcadia. Can anybody actually think of a change to the rules on how dividends are taxed, or on how husband and wife’s tax affairs are treated, that would actually improve things whilst stopping what he did? The only thing I can think of is to give a judge scope to decide what is ‘reasonable’, but that’s a slippery slope.

No takers for Luis’s questions?

@18

No takers to mine or Tims points either.

Ok let’s flip this a bit. Say the protests have an affect in tightening law that’s acceptable to the protesters and uk uncut claim victory.

How long will these changes take to implement into law?
Would they pass commons and lords votes to even become law?
Do protesters accept that any historical claimed avoidance can’t then be chased after, only going forward.
Do the protesters stop at announcement or implementation of new laws?
What do they do then with the movement? Is it nul & void then ?

You’d be looking at some 18 months min, and any changes in law if they did happen would be severely watered down under pressure from business leaders and party backers.

In that time cuts will have truly bitten hard and the opportunity to fight the cuts will have long passed. Loads will have lost jobs and services they rely on.

It’s a valid debate on laws being held at entirely the most inappropriate point in time.

Luis @17,

Why can’t campaigners try to understand what they are campaigning about?

Protesters are more interested in the story than the truth / detail. They think they have competent authorities (Murphy, the Guardian etc) on whom they can rely. And who can blame them when it comes to taxes?

Why do idiots like Murphy play such a big role?

The BBC emailed me once and said, “could we interview you?”

I mention this not because it’s something amazing but because it proved to me that competence isn’t required to become an authority. It’s the squeaky wheel that gets the oil and boy, do Murphy co. squeak.

Why is there so much exaggeration and why are so many misleading claims made (in the OP here – you compare taxes paid on UK profits against global profits including asset sales … why do that?).

Perhaps the OP is incompetent. Perhaps he doesn’t particularly care for the truth but the story.

Is it really true that it’s better to have people getting angry and waving placards but holding a set of incoherent and inconsistent beliefs, and that if people somehow stopped to understand what the fuck they were talking about, the “movement” would suffer?

Yes, it’s better for the movement that people stay angry.

Tim W:

“1) Vodafone. The claim is that profits made from selling phones in Germany, from German shops, to German customers, should be taxed in the UK because Vodafone is, in the end, a UK company.

2) Boots, now a Swiss company, should be paying taxes in the UK from selling stuff in the UK, though UK shops, to UK peeps. Because tax should be paid where the profits are made, not just where the company resides.

These are incompatible views of course.”

And you are happy that tax isn’t paid in either case.

“3) Arcadia. Arcadia does pay corporation tax in the UK one what it makes from selling stuff from UK shops to UK peeps in the UK. Here the demand is that Lady Green, who is not a UK resident, not domiciled here, should still be paying UK income tax on her income. This is entirely barking.”

Only if you’re an idiot and you’re deliberately going to miss the real issue here – let me educate you:

“Philip Green is not a non-dom. He lives in the UK. He works in the UK. He pays tax on his salary in the UK. All seems to be in order. Until you realise that Philip Green does not actually own any of the Arcadia group that he spends every day running. Instead, it is in the name of his wife who has not done a single day’s work for the company. Mrs Green lives in Monaco, where she pays not a penny of income tax.

In 2005 Philip Green awarded himself £1.2bn, the biggest paycheck in British corporate history. But this dividend payout was channeled through a network of offshore accounts, via tax havens in Jersey and eventually to Green’s wife’s Monaco bank account. The dodge saved Green, and cost the tax payer, close to £300m. This tax arrangement remains in place. Any time it takes his fancy, Green can pay himself huge sums of money without having to pay any tax.”

Here’s a genuine question. Why can’t campaigners try to understand what they are campaigning about?

Just because they might not know every detail doesn’t mean they don’t know what they’re campaigning about.

Diamond also confirmed to Umunna that the bank had 30 subsidiary companies in the Isle of Man, 38 in Jersey and 181 in the Cayman Islands but stressed that the bank was making efforts to liquidate some of these of operations in the crown dependencies.

http://www.guardian.co.uk/business/2011/feb/18/barclays-bank-113m-corporation-tax

Those subsidiary companies are just for fun are they?

Why do idiots like Murphy play such a big role?

What is it with right-wingers and being arrogant? In my opinion, Richard Murphy isn’t an idiot. In fact, I think he really knows his stuff.

Why is there so much exaggeration and why are so many misleading claims made (in the OP here – you compare taxes paid on UK profits against global profits including asset sales … why do that?). Is it really true that it’s better to have people getting angry and waving placards but holding a set of incoherent and inconsistent beliefs, and that if people somehow stopped to understand what the fuck they were talking about, the “movement” would suffer? I don’t understand – they way I see it, if people had any integrity, they’d respond to some of the points Worstall makes above with something like “ah, yes, some good points there. It doesn’t make much sense to be both angry about Vodafone and about Boots at the same time. Perhaps I ought to reconsider my views”.

Well how about Worstall acting with a bit of integrity? He supposedly didn’t understand why people had a problem with Philip Green so I told him here:

https://liberalconspiracy.org/2011/01/22/how-could-ukuncut-deal-with-attempts-at-sabotage/#comment-227587

…and then he continues to pretend not to really understand the issue, as UK Uncut see it.

Then there is this one which is even better: Boots. He acted as if there was no argument when it came to their taxes but Richard Murphy had a different opinion, which I reminded him of in the same post above. He then ignored that in the following post and acts again as if there is no argument to what he says.

Where is the integrity there, Luis?

https://liberalconspiracy.org/2011/02/14/four-reasons-why-tax-avoidance-makes-us-all-worse-off/#comment-236260

But they won’t, they’ll just go on the attack and accusing him of defending is corporate overlords.

Well I haven’t seen that happen but I do notice that he’s not actually saying that at least ONE of those two companies should pay tax.

PS: I hope all this blockquoting works.

I have to admit, it makes it a hell of a lot easier to read.

@UKcuts:

“No takers to mine or Tims points either.”

I imagine at least part of the reason for that is because they have previously been responded to and Tim has just carried on as if no-one said anything! It is really quite tiresome having to go over the same points, over and over again.

Sorry for yet another post but I forgot to include this link before:

http://www.ukuncut.org.uk/targets

If anyone from UK Uncut reads this, well done for separating out the targets on to their own pages as its better for linking. Also, I think that you should respond to some of the regular critical comments regarding your targets, perhaps in a Q&A way, so that people can quickly copy and paste answers:

Q: Isn’t it the case with Boots that …
A: No because …

“In my opinion, Richard Murphy isn’t an idiot. In fact, I think he really knows his stuff.”

That isn’t going to make all that many people take you seriously.

“Instead, it is in the name of his wife who has not done a single day’s work for the company. Mrs Green lives in Monaco, where she pays not a penny of income tax.”

This is known as “capitalism”.

The people who own things get a different set of payments from people who work in those things that they own. The managers of BP get paid wages: the owners of BP get paid dividends.

Now, perhaps your gripe is with that system, but if not, there’s nothing to distinguish the arrangements here, Lady Green and the shareholders of BP, British Gas, Rio Tinto. Rolls Royce or any other company.

“and cost the tax payer, close to £300m”

It did not cost the taxpayer anything. UK tax is not payable on dividends paid to people who are not UK resident or domiciled. There was never any tax due: so it could not have cost the taxpayer anything.

“Then there is this one which is even better: Boots. He acted as if there was no argument when it came to their taxes but Richard Murphy had a different opinion, which I reminded him of in the same post above.”

The Boots paying little tax is very little to do with their having move head office to Switzerland. It’s to do with their having taken on loads of debt. And interest in debt is an allowable expense. Now, if that’s what you are complaining about, fair play. But that’s not what I’ev seen people complaining about: it seems to have been all about the move, not the debt.

And here’s the clincher: we don’t actually know that less tax is being pai as a result. Sure, we know that less oporation tax is being paid by Boots. But the interest that they pay goes to other people: and interest is taxed when people receive it (dividends are, in part, taxed at the company level before they are sent).

So, sure, Boots is paying less corporation tax. But it’s actually possible (and there’s no real way of finding this out) that more tax is being paid on the interest being received than would originally have been paid.

That’s one of the things that Murphy’s not been telling you, isn’t it?

Matt,

As Sunny & Ellie have chosen not to continue the debate (can’t think why), perhaps you can respond to my Q’s in 19 & 9.

Matt

I am not an arrogant right winger, I am an arrogant left winger. If you cannot see that Murphy is a fool, your loss. If you don’t like how Tim Worstall conducts himself, is your best defense “we’re no worse than him?” I am looking for somebody somewhere on the “tax avoidance protesters” side of the debate to at least acknowledge the inconsistency about wanting to tax UK companies on foreign profits and complaining about foreign companies not paying tax on UK profits. I quite understand what Green has done, I am looking for somebody on the “tax avoidance protesters” side of the debate to acknowledge the problem that changing the law to tax people from country A on dividends earned in country B could lose us as much tax revenues as it gets us, and that changing the laws so that people from county A have to pay tax of dividends in country B if they are married to somebody who works in country B but do not live there, , or changing the law to tax households rather than individuals, or however else you could fix the situation, might do more harm than good. I am looking for somebody to show more than zero interest in the practicalities of the matter, rather than just merrily bandy around the most hysterical version of events and regard anybody who tries to point out some of the facts of the matter as an enemy of the people.

Matt,

Sorry for yet another post but I forgot to include this link before:

http://www.ukuncut.org.uk/targets

If anyone from UK Uncut reads this, well done for separating out the targets on to their own pages as its better for linking. Also, I think that you should respond to some of the regular critical comments regarding your targets, perhaps in a Q&A way, so that people can quickly copy and paste answers:

Q: Isn’t it the case with Boots that …
A: No because …

That’s all well and good, but UK Uncut don’t quite give the full story, do they?

If you look at their page on Vodafone, for example, there is no mention of the CFC rules, which are key to this.

For the last ten years Vodafone have been fighting tooth and nail to avoid paying the UK government around £6bn in tax. Court case followed court case, and eventually HM Revenue and Customs won a decisive victory. Vodafone were on the ropes and all that was needed was a couple more government knocks to finally make the communication giant pay up.

It simply isn’t true that was “all that was needed” as Private Eye – which UK Uncut prays in aid, mind – and others have made clear.

That isn’t going to make all that many people take you seriously.

In your opinion.

This is known as “capitalism”.

Yes, Tim, well done. But like Tim J, you are completely missing the point. And because I don’t think that either of you two are stupid, I have to assume that you’re missing the point deliberately.

The people who own things get a different set of payments from people who work in those things that they own. The managers of BP get paid wages: the owners of BP get paid dividends.

Now, perhaps your gripe is with that system, but if not, there’s nothing to distinguish the arrangements here, Lady Green and the shareholders of BP, British Gas, Rio Tinto. Rolls Royce or any other company.

I’m going to explain the issue as simply as I can. Philip Green is doing the work. Mrs Green isn’t. Do you understand so far? (Sorry to others that this will sound patronising!) Instead of the shares being in Philip’s name, they’re in Mrs Green’s name, despite the fact that he’s the one doing the work. She hasn’t done anything to EARN those dividends.

This is a very simple issue. If you truly can’t understand UK Uncut’s gripe here then I can’t help you.

It did not cost the taxpayer anything. UK tax is not payable on dividends paid to people who are not UK resident or domiciled. There was never any tax due: so it could not have cost the taxpayer anything.

Again, you’re just missing the point.

That’s one of the things that Murphy’s not been telling you, isn’t it?

Except that Murphy replied to that point of yours didn’t he? Anyway, this is all missing my point, which is that you acted as if there was no argument when it came to the taxes of Boots when you knew that Murphy had a different opinion to you. It’s a lack of integrity.

I am not an arrogant right winger, I am an arrogant left winger.

Ha ha ha! Great!

So tell me, in what ways are you left-wing?

If you cannot see that Murphy is a fool, your loss.

But where is your justification for saying this?

If you don’t like how Tim Worstall conducts himself, is your best defense “we’re no worse than him?”

Perhaps it’s only natural that people are going to find it hard to reply in a saint-like way to someone who isn’t like that.

I am looking for somebody somewhere on the “tax avoidance protesters” side of the debate to at least acknowledge the inconsistency about wanting to tax UK companies on foreign profits and complaining about foreign companies not paying tax on UK profits.

Perhaps they should acknowledge it. But I don’t hear the non-protestors arguing that Vodafone should be paying that £6bn in Germany.

I quite understand what Green has done, I am looking for somebody on the “tax avoidance protesters” side of the debate to acknowledge the problem that changing the law to tax people from country A on dividends earned in country B could lose us as much tax revenues as it gets us, and that changing the laws so that people from county A have to pay tax of dividends in country B if they are married to somebody who works in country B but do not live there, , or changing the law to tax households rather than individuals, or however else you could fix the situation, might do more harm than good. I am looking for somebody to show more than zero interest in the practicalities of the matter, rather than just merrily bandy around the most hysterical version of events and regard anybody who tries to point out some of the facts of the matter as an enemy of the people.

Perhaps the problem here is that people in your position are happy to criticise protestors but don’t then suggest a solution to the issue. So instead of saying, “well that won’t work but how about this instead?”, people like you simply say, “well that won’t work”.

And calling it “hysterical” is over-egging it yourself.

That’s all well and good, but UK Uncut don’t quite give the full story, do they?

If you look at their page on Vodafone, for example, there is no mention of the CFC rules, which are key to this.

It simply isn’t true that was “all that was needed” as Private Eye – which UK Uncut prays in aid, mind – and others have made clear.

A number of things have been said since that post by Tim J. Including, in particular, a follow-up article by Private Eye that made it clear – and I forget how they put this – that the CFC rules weren’t relevant to whether Vodafone owed that money or not.

Matt,

You say Mrs green has done nothing to earn dividends.

I have shares in companies I don’t work for, and receive dividends on them just as.Mrs green does.

There are also plenty of companies owned by people who.don’t get involved with running or day to day issues and simply collect profits &/or a salary.

On this you’re entering into an impossible argument.

“I’m going to explain the issue as simply as I can. Philip Green is doing the work. Mrs Green isn’t. Do you understand so far? (Sorry to others that this will sound patronising!) Instead of the shares being in Philip’s name, they’re in Mrs Green’s name, despite the fact that he’s the one doing the work. She hasn’t done anything to EARN those dividends.”

You don’t earn dividends. That’s why they’re called unearned income, along with interest.

Blimey, I’ve laid it out for you already. She gets dividends because she owns shares. She doesn’t have to do any work, “earn” anything. That’s just how capitalism works, those who own the capital get the dividends and interest from the use of the capital.

“But I don’t hear the non-protestors arguing that Vodafone should be paying that £6bn in Germany.”

I have consistently said that those profits should be taxed in Germany in whatever manner Germany wants to tax them. As, in fact, those profits were taxed in Germany in the manner Germany wanted to tax them.

“Private Eye that made it clear – and I forget how they put this – that the CFC rules weren’t relevant to whether Vodafone owed that money or not.”

The entire thing was about CFC rules. There is no doubt that if Vodafone Luxembourg had been Vodafone Cayman, that more tax would have been owed. But it wasn’t, so there was a conflict between the CFC rules and the EU’s rules on freedom of establishment. That’s exactly what the High Court case (which Vodafone won) and the Court of Appeal case (which HMRC sorta won) were about. If Private Eye are saying it’s not about CFC then Richard Brooks (the journo responsible) is writing rather more about what he’d like to be true than actual reality.

Matt,

that’s right, I must be right wing: see how I’m complaining about the righteous ones talking bollocks. I can see your affinity to Murphy here, that’s how operates.

My point was there might not be a solution to the Green dividends maneuver and that it might be worth perhaps try to understand the practicalities involved before proceeding directly to outrage. But whatever. I’m sure you’re right, the anti-tax avoidance movement will be far better off it never stops to think about how taxation actually works and what sort of reforms are feasible and desirable – doing that would be to cede ground to your enemies.

Matt,

A number of things have been said since that post by Tim J. Including, in particular, a follow-up article by Private Eye that made it clear – and I forget how they put this – that the CFC rules weren’t relevant to whether Vodafone owed that money or not.

I don’t recall seeing that article. Unfortunately the Eye’s articles on this are no longer online. However, Brooks’s evidence to the Treasury Committee is available online: “The group considering “monetary assets” includes the tax director of Vodafone, whose multi-billion pound tax avoidance using transactions covered by this very aspect of CFC law has been extensively reported by Private Eye”. Brooks seems to believe the CFC rules are relevant – his position is that they disadvantage SMEs.

It would be odd if people claimed the CFC rules were irrelevant given the 200 mentions of CFC in the Vodafone 2 v HMRC judgements handed down by the High Court and the Court of Appeal.

As I understand the Eye’s series of articles, their position is that HMRC should have pressed the case in the Supreme Court. I think their position is one of principle, to get a decision. But suppose HMRC lost?

…pressed on. the case in the Supreme Court

@33:

“You say Mrs green has done nothing to earn dividends. I have shares in companies I don’t work for, and receive dividends on them just as.Mrs green does.”

How did you obtain those shares? Were you given them by a friend? A relative? Did you find them under the doormat one day?

If you *bought* the shares, then the dividends you receive are a return on the money you invested, which represents your labour. It is not so with Mrs Green. Rather, it’s very clearly a case of getting her husband out of a few £s in tax, and represents the worse of cynical capital accumulation.

Tom.

Tom,

that’s interesting – was Mrs Green gifted shares in Arcadia by Mr Green? So i s there potential for some legislation to tax gifted shares, or something? What are the current rules on taxing gifts between family members, or gifts in general? [surprised as matt might be to learn this, I would very much like to prevent the likes of Green doing what they do].

@39. Not sure whether they were gifted to her or whether the company was set up that way in the first place. Sorry, dunno.

But transfers between spouses are tax free, always. No tax due at all.

There is actually an area worthy of discussion here. Once upon a time it was the household that was taxed, not each individual in it (well, for married couples anyway). So who actually owned an asset wasn’t very important.

But of course now we, righteously, have individual taxation. The woman and the man are separate indivuduals and are taxed accordingly (Murphy has quite seriously suggested that this should be reversed and feminism be damned).

But now, of course, that transfer of assets can make a difference. So maybe that’s where the change should be made, if any change there’s going to be?

Of course, for just about everyone this will be an absolute nightmare, taxing the transfer of a house or a car or even gifts over £3,500 (?) between man and wife.

For there aren’t all that many people who are UK resident and domiciled who are married to someone who is neither, and to whom an asset can be switched without tax needing to be paid on the income from it.

Tim,

I guess a law could tax gifts above £1m of something. And would it have to tax the giver not the receiver, otherwise if the receiver was a foreigner like Mrs Green, the applicable “receiving gifts” tax would be imposed where she lives?

:41, looking it up, Tina Green owned Tavira outright (ie, the holding company) before it bought Arcadia.

So Green never actually gave her the shares at all.

Yes, I know we could all argue about this, but in terms of the pieces of paper that have moved about, a company which tina Green owned bought Arcadia and employed her husband as the manager.

TW

what did she do, buy it for £1 or something? I’m sure tax laws are capable of nabbing people who sell assets below fair value, or something

@38

I was given my shares gratis when a financial floated who I’m a cust of.

You say Mrs green has done nothing to earn dividends.

I have shares in companies I don’t work for, and receive dividends on them just as.Mrs green does.

There are also plenty of companies owned by people who.don’t get involved with running or day to day issues and simply collect profits &/or a salary.

On this you’re entering into an impossible argument.

Firstly, it’s not just me, it’s UK Uncut as well. Secondly, I disagree. I think this is a very straightforward argument.

You don’t earn dividends. That’s why they’re called unearned income, along with interest.

Blimey, I’ve laid it out for you already. She gets dividends because she owns shares. She doesn’t have to do any work, “earn” anything. That’s just how capitalism works, those who own the capital get the dividends and interest from the use of the capital.

You’re missing the point! How come she gets millions in dividends and I don’t?

The entire thing was about CFC rules.

Do you and others understand yet why you just get ignored after a while? It’s because you go on and on about the same subject.

There is no doubt that if Vodafone Luxembourg had been Vodafone Cayman, that more tax would have been owed. But it wasn’t, so there was a conflict between the CFC rules and the EU’s rules on freedom of establishment. That’s exactly what the High Court case (which Vodafone won) and the Court of Appeal case (which HMRC sorta won) were about. If Private Eye are saying it’s not about CFC then Richard Brooks (the journo responsible) is writing rather more about what he’d like to be true than actual reality.

Okay, what I should have done was quote (once again) what Private Eye said in its follow-up article:

Vodafone also told the Eye that HMRC “concurred” with it that a 2007 European Court decision (involving Cadbury) meant that “we clearly had no future liability”. Yet HMRC’s own official guidance-notes in response to that case, based on expert legal advice, show that where income is diverted to a tax haven in precisely the way Vodafone did it, “no application [that the profits won’t be taxed] is likely to be granted”.

What I should have said in response to ukliberty (in my post 239052) was that the CFC rules didn’t matter (at this point) because “HMRC’s own official guidance-notes in response to that case, based on expert legal advice, show that where income is diverted to a tax haven in precisely the way Vodafone did it, “no application [that the profits won’t be taxed] is likely to be granted””.

that’s right, I must be right wing: see how I’m complaining about the righteous ones talking bollocks.

What are you on about?

I can see your affinity to Murphy here, that’s how operates.

Again, what are you on about?

The reason that I laughed before was not because I didn’t believe that you were left-wing but because you seemed to think that it was perfectly okay to be arrogant! And why didn’t you answer my perfectly reasonable question about in what ways you are left-wing?

And why didn’t you provide any justification for saying that Murphy is a fool?

My point was there might not be a solution to the Green dividends maneuver and that it might be worth perhaps try to understand the practicalities involved before proceeding directly to outrage. But whatever. I’m sure you’re right, the anti-tax avoidance movement will be far better off it never stops to think about how taxation actually works and what sort of reforms are feasible and desirable – doing that would be to cede ground to your enemies.

What’s wrong with you? I’m engaging you in perfectly reasonable discussion and you’re becoming hysterical.

My point here is that people on your side of the argument always seem to be looking for holes in the argument, with no follow-up as to what should happen instead. If you just had a problem with the Philip Green situation then that wouldn’t be too bad, but you also have a problem with taking on both Vodafone and Boots at the same time. Just who WOULD you be happy with protests against?

I don’t recall seeing that article. Unfortunately the Eye’s articles on this are no longer online. However, Brooks’s evidence to the Treasury Committee is available online: “The group considering “monetary assets” includes the tax director of Vodafone, whose multi-billion pound tax avoidance using transactions covered by this very aspect of CFC law has been extensively reported by Private Eye”. Brooks seems to believe the CFC rules are relevant – his position is that they disadvantage SMEs.

It would be odd if people claimed the CFC rules were irrelevant given the 200 mentions of CFC in the Vodafone 2 v HMRC judgements handed down by the High Court and the Court of Appeal.

See my response to Tim W.

As I understand the Eye’s series of articles, their position is that HMRC should have pressed the case in the Supreme Court. I think their position is one of principle, to get a decision. But suppose HMRC lost?

Perhaps then a precedent would have been set, but my view is that by not pushing things HMRC lost out on billions and now every other large corporation will want a similarly cushy deal. So in a way a precedent has now been set (with HMRC the loser).

You don’t earn dividends. That’s why they’re called unearned income, along with interest.

Alright, how about “deserve”, what did she do to deserve those dividends?

Blimey, I’ve laid it out for you already.

But as I said before, I know how capitalism works, you’re just missing the point.

She gets dividends because she owns shares. She doesn’t have to do any work, “earn” anything. That’s just how capitalism works, those who own the capital get the dividends and interest from the use of the capital.

This issue has nothing to do with capitalism. It’s do with morals. Seriously Tim, I’m getting annoyed with this now. Stop arguing about the law. Stop arguing about capitalism. If you really don’t understand why UK Uncut has an issue with what Philip Green did then you really should stop being arrogant because you’re obviously not actually particularly bright. (And for any lurkers reading, I know that sounds harsh but if you’ve being following this argument then you should be able to see that it’s justified.)

I shall repeat myself. This issue has nothing to do with the law. It has nothing to do with capitalism. It is to do with morals. Don’t reply to this post if you’re just going to go on about capitalism etc.

That £300m could have paid for a hell of a lot. Just how greedy can a person be?

So your argument actually is “she got £300 million and I didn’t, that’s not fair, Waaah”?

OK, as long as we know what your argument is that’s great. And now we can dismiss you as some teenage Trot. Great.

And as to CFC and Vodafone: if HMRC had lost in the Supreme Court, as is possible (note! possible!) then yes indeed that would have created a precedent.

Which means that HMRC would have lost fortunes from all the other cmopanies trying the same thing. By not having allowed a precendent to be set in stone, they can now negotiate and claim something, not nothing, from all of those other companies.

matt.

it’s not a sensible question, it is stupid and annoying. I had already told you my political sympathies, to ask it suggests you think I might be lying. Why would you not think I was still lying if I composed a little left wing pledge of allegiance for you? I don’t need to “provide evidence” re: Murphy, it is evident in most everything he writes. Would you be satisfied with a link to his blog, or were you hoping I’d compile a dossier of his top 10 stupidest utterings?

You think I “seem to think that it was perfectly okay to be arrogant”. Let me try an argument by analogy:
m: you dirty Irishman!
l: I’m not a dirty Irishman, I’m a dirty Scotsman
m: you seem to think it’s perfectly ok to be dirty
(and do you really think arrogance is the preserve of the right? grow up)

I think you have rather lost touch with my point. I had expressed frustration that in all the manifestations and examples of the “anti-tax avoidance movement” I see here, in posts and in comments, and elsewhere, I very rarely see any interest in the practicalities of taxation – and this is what really gets up my nose – when some of the issues are pointed out, no inclination to amend views. Rather go back to talking about things like writing off past losses as if it is tax avoidance. Personally, I think that if you are concerned about corporate tax avoidance, that’s a reason to be interested in the details. I don’t think the fact that I cannot present you with an immediately implementable policy change to solve every problem changes that. You ask what sort of protests I would support – I can tell you that my support of protests is declining in the quantity of bollocks spouted.

you really should stop being arrogant because you’re obviously not actually particularly bright. (And for any lurkers reading, I know that sounds harsh but if you’ve being following this argument then you should be able to see that it’s justified.)

= ad hominem = losing the argument

Matt,

As I understand the Eye’s series of articles, their position is that HMRC should have pressed the case in the Supreme Court. I think their position is one of principle, to get a decision. But suppose HMRC lost?

Perhaps then a precedent would have been set, but my view is that by not pushing things HMRC lost out on billions and now every other large corporation will want a similarly cushy deal. So in a way a precedent has now been set (with HMRC the loser).

Fair enough, that’s your view and you’re entitled to it; HMRC could have pressed on and won and received however many billions more than the £1.2bn.

But HMRC could have pressed on and lost and not only would Vodafone have paid nothing but the loss would strengthen the positions of the other 100 or so companies with similar arrangements, meaning that they might not have to pay anything either.

In the end, HMRC decided to sit with Vodafone at the negotiating table, and HMRC got some money out of that. And HMRC can do the same with the other 100 or so companies, too.

Meanwhile, the rules are being changed. (Yes, I know that Brooks doesn’t think much of the negotiations.)

sorry, I screwed up my html.

Matt,

This issue has nothing to do with capitalism. It’s do with morals. Seriously Tim, I’m getting annoyed with this now. Stop arguing about the law. Stop arguing about capitalism. If you really don’t understand why UK Uncut has an issue with what Philip Green did then you really should stop being arrogant because you’re obviously not actually particularly bright. (And for any lurkers reading, I know that sounds harsh but if you’ve being following this argument then you should be able to see that it’s justified.)

I shall repeat myself. This issue has nothing to do with the law. It has nothing to do with capitalism. It is to do with morals. Don’t reply to this post if you’re just going to go on about capitalism etc.

UK Uncut is a campaigning organisation and as such is more interested in results than the finer details. Again, that’s their view and they are entitled to it.

What it means though is that some of what they say might not be rooted in the facts. And the problem with saying things like, “stop arguing about the law” is that it’s the law here that is at issue. We don’t and can’t run our society on ‘morals’ we have to run it on a set of rules. The rules may of course be based on morals but the point is that something has to be written on paper so that, if there is an argument about the rules, a neutral and informed decision-maker can hear both sides of the argument, look at the rules, and hand down a judgement. We can’t do that with morals.

If you follow Tim Worstall and Luis Enrique (I have no idea why you’re offended by Luis – sorry Tim! 😉 and others you will see that they not only criticise aspects of the tax system and individual behaviour but also call for improvements including tax simplification. Precedent suggests it is inevitable that complex rules leads to people taking advantage. We have a complicated tax system. I can’t remember who said it (Mark Wadsworth, I think), but it was something along the lines of, “every year a new volume equivalent to the collected works of Tolkien lands on my desk, and it’s not a replacement but in addition to all the volumes that have gone before”. You can get an idea of how complicated the Vodafone 2 case is from the judgements I linked to @36.

In my view their arguments are well worth reading even if you disagree.

And you’ve got to realise that criticism of something (e.g. UK Uncut’s position on Vodafone etc) does not entail support for some other thing (eg. Vodafone’s tax arrangements) – too many people on the Internet make this error.

@45

“Do you and others understand yet why you just get ignored after a while? It’s because you go on and on about the same subject.”

Matt people like me, Tim, Louis get ignored because uk uncut can’t answer certain questions about tax and relation to their protests.

Instead, just as with a certain US religious group joined by celebs, defense is left to the followers whom the.leaders hide behind. And the followers can’t answer with anything other than the info provided by organisers/leaders of the group.

If you’ve followed the group as close as you say, you’ll see the initial defense comes from the.leaders, and when replied to they disappear and leave people like you to reply.

I’m amazed people don’t see an issue with this.practice.

Sorry Luis for mispelling your name.

just trying to end the italics.

tryingagain

Tim Worstall:

So your argument actually is “she got £300 million and I didn’t, that’s not fair, Waaah”?

No, my argument is not actually that, Waaah. My argument is the perfectly reasonable one that it’s immoral.

If you’re referring to where I said, “How come she gets millions in dividends and I don’t?”, the point was not for one moment that I’m actually bothered that I’m not getting that money, but to try and get through to you that it was actually necessary for her to have done something to get that money.

I’m sorry that because you couldn’t simply revert to talking about capitalism that you’re now lashing out.

OK, as long as we know what your argument is that’s great.

Straw man point.

And now we can dismiss you as some teenage Trot. Great.

I am not a teenage Trot.

I’m sorry that because you couldn’t simply revert to talking about capitalism that you’re now resorting to abuse.

As someone else has said:
“It’s legal” is the dying argument of those who don’t have ethics.

And as to CFC and Vodafone: if HMRC had lost in the Supreme Court, as is possible (note! possible!) then yes indeed that would have created a precedent.

Which means that HMRC would have lost fortunes from all the other cmopanies trying the same thing. By not having allowed a precendent to be set in stone, they can now negotiate and claim something, not nothing, from all of those other companies.

The above isn’t actually responding directly to what I said:
“Perhaps then a precedent would have been set, but my view is that by not pushing things HMRC lost out on billions and now every other large corporation will want a similarly cushy deal. So in a way a precedent has now been set (with HMRC the loser).”

cjcjc:

you really should stop being arrogant because you’re obviously not actually particularly bright. (And for any lurkers reading, I know that sounds harsh but if you’ve being following this argument then you should be able to see that it’s justified.)

= ad hominem = losing the argument

Quoting out of context = losing the argument. Here is the full sentence:

If you really don’t understand why UK Uncut has an issue with what Philip Green did then you really should stop being arrogant because you’re obviously not actually particularly bright.

Quite how that sentence in full is ad hominem I don’t know. You are welcome to explain, cjcjc, or whatever your real name is.

Luis Enrique:

it’s not a sensible question, it is stupid and annoying.

What question are you referring to? Do you mean this one: “What are you on about?” Or this one: “Again, what are you on about?” Or some other one? Do you understand why I laughed?

I had already told you my political sympathies, to ask it suggests you think I might be lying.

If you are referring to this question, “And why didn’t you answer my perfectly reasonable question about in what ways you are left-wing?”, I am quite happy to make clear that I am NOT suggesting that you are lying, I was asking because you don’t seem to have anything to say in support of the anti-cuts movement.

Why would you not think I was still lying if I composed a little left wing pledge of allegiance for you?

Like I say, I wasn’t suggesting that you were lying.

I don’t need to “provide evidence” re: Murphy, it is evident in most everything he writes. Would you be satisfied with a link to his blog, or were you hoping I’d compile a dossier of his top 10 stupidest utterings?

Well I would like SOMETHING! As I said before, I think that he knows his stuff, so for you just to call him an idiot or whatever doesn’t get anyone anywhere does it? Tell me something, what person who is at least a bit prominent in the media do you respect? Now how about if I was to call them an idiot – would you then just accept that they were an idiot?

You think I “seem to think that it was perfectly okay to be arrogant”. Let me try an argument by analogy:
m: you dirty Irishman!
l: I’m not a dirty Irishman, I’m a dirty Scotsman
m: you seem to think it’s perfectly ok to be dirty

Yes, that was exactly my point!

(and do you really think arrogance is the preserve of the right? grow up)

That’s a straw man point followed with mild abuse. I didn’t say that it was the preserve of the right, I indicated that it seemed to be common.

I think you have rather lost touch with my point. I had expressed frustration that in all the manifestations and examples of the “anti-tax avoidance movement” I see here, in posts and in comments, and elsewhere, I very rarely see any interest in the practicalities of taxation – and this is what really gets up my nose – when some of the issues are pointed out, no inclination to amend views. Rather go back to talking about things like writing off past losses as if it is tax avoidance. Personally, I think that if you are concerned about corporate tax avoidance, that’s a reason to be interested in the details. I don’t think the fact that I cannot present you with an immediately implementable policy change to solve every problem changes that.

Fair enough. It’s just that it comes across as, “let’s work out every detail of the tax changes we would like before doing anything, let’s consider all the possible unforeseen consequences before doing anything, let’s check that there are no contradictions in anything we say before doing anything, and let’s make sure that everyone who comes along to one of our protests knows every detail before we allow them to join us – in short, let’s be really perfectionist”.

As someone who went along to the protest on Saturday said:
“It is a matter of media strategy rather than policy prescription.”

You ask what sort of protests I would support – I can tell you that my support of protests is declining in the quantity of bollocks spouted.

It may surprise you to know that I’m not actually a great fan of protests. Where this campaign is different is that they know the importance of getting media attention.

ukliberty:

I appreciate that we can’t run our society on morals, I was just trying to get through to Tim W that that was what UK Uncut’s gripe was about. And I agree with tax simplification, but part of the problem is that people keep finding new ways of getting round “paying their dues” so the system has to become more complicated. One answer to that is to have a general anti-avoidance rule, but people criticise that too.

And you’ve got to realise that criticism of something (e.g. UK Uncut’s position on Vodafone etc) does not entail support for some other thing (eg. Vodafone’s tax arrangements) – too many people on the Internet make this error.

I appreciate that error but my issue with those people is that they don’t normally suggest an alternative.

Oops, the second bit that is block-quoted in my above post shouldn’t have been.

cjcjcj:

= ad hominem = losing the argument

Losing what argument? As far as I can see, there has been no argument to lose. Have you actually been following this thread or do you just jump in to make moany comments against people whose political views you disagree with?

Let me explain:

Tim W has been going on and on that tax wasn’t paid in the Greens’ case because of capitalism.

I have not disagreed with this – there is no argument.

What I (and UK Uncut) have been saying is that Mrs Green didn’t do the work and so didn’t deserve that money. (And so that by Mrs Green getting the money for Philip Green’s “labour” £300 million in tax was avoided.)

Tim W has repeatedly ignored the moral issue and just gone on and on about capitalism.

I have been repeatedly trying to get through to Tim W that the issue here isn’t to do with capitalism, it’s to do with morals. Crucially, CJ, Tim W hasn’t actually argued against this, the morals of what Philip Green did, he has just gone on and on about capitalism.

So there has been no argument to lose, it’s just that, frankly, Tim W has been acting a twat. And I make no apology for saying that, it’s perfectly justified in the circumstances (and nor does it lose me some supposed argument, although I have no doubt that you, Tim or someone else will try to make out that it does).

” My argument is the perfectly reasonable one that it’s immoral.””

What is immoral? That someone gets £300 million? That the owner of a company gets dividends from a company? That a foreigner doesn’t get taxed in the UK?

“I am not a teenage Trot.”

If the immorality is either 1 or 2 then yes, you do seem to be a teenage Trot.

” Which means that HMRC would have lost fortunes from all the other cmopanies trying the same thing. By not having allowed a precendent to be set in stone, they can now negotiate and claim something, not nothing, from all of those other companies.

The above isn’t actually responding directly to what I said:
“Perhaps then a precedent would have been set, but my view is that by not pushing things HMRC lost out on billions and now every other large corporation will want a similarly cushy deal. So in a way a precedent has now been set (with HMRC the loser).””

You seem not to understand what “precedent” means. This is a legal term. If the Supreme Court rules that Vodafone were just fine in what they were doing then this means that this is now the law for all companies. This is what “precedent” means in the Common Law. By not taking the case to hte Supremes then HMRC has avoided a precedent being set.

“Tim W has been going on and on that tax wasn’t paid in the Greens’ case because of capitalism.

I have not disagreed with this – there is no argument.

What I (and UK Uncut) have been saying is that Mrs Green didn’t do the work and so didn’t deserve that money.”

Excellent, so the gripe is that those who do not do the work do not deserve the money. Meaning it is indeed capitalism you’re complaining about: you are indeed a teenage Trot.

Matt,

*Any company can gift shares to whoever they like.for whatever reason.
*All shareholders of a.company can earn dividends on shares they own if one is paid.
*You don’t have to be a worker or owner of or anyway associated with a company to hold shares in it.
*Non sims don’t pay tax on these

We’re just going round and.round a moralistic argument with no legal backup to the points you’ve raised.

Even.IF today your issues with the law we announced as being cracked down on, it wouldn’t allow for this claimed tax due from Mr Green or Vodafone to be collected. I hope you do know this.

It’d also be 18months plus before it actually gets implemented, and likely watered down.

Which makes Vodafone & green moot points

“This issue has nothing to do with law”

That point of view does make it quite hard to have an adult conversation about the proper application of tax law.

“Does the precedent set by Cadbury Scweppes invalidate the UK Controlled Foreign Companies tax system?”

“It’s not fair!”

Generally people who feel they are making a strong argument don’t call people “twats”.

I receive dividends from many companies for which I do not work.
Is that immoral?
I pay no tax of many of those dividends as the shares are held in my pension plan.
Is that immoral?

*Asserting* immorality is not the same as *arguing* immorality.

And you do, as Luis has consistently pointed out, unfortunately have to worry about the *details* if you wish to make changes. You have to worry very much about the details.

What is immoral? That someone gets £300 million? That the owner of a company gets dividends from a company? That a foreigner doesn’t get taxed in the UK?

That’s irrelevant, all that I’ve been trying to get through to you is why UK Uncut have had an issue with Philip Green. Do you understand the issue that they have with him or not?

If the immorality is either 1 or 2 then yes, you do seem to be a teenage Trot.

Ah, once again ignoring the issue. The issue is that Philip Green deliberately paid his wife to avoid the tax. I am not a teenage trot.

You seem not to understand what “precedent” means.

You seem unable to read basic English. I said: “So in a way a precedent has now been set (with HMRC the loser).” Read it again.

Excellent, so the gripe is that those who do not do the work do not deserve the money. Meaning it is indeed capitalism you’re complaining about: you are indeed a teenage Trot.

Where is the logic in that paragraph? How does immorality flow into not liking capitalism and therefore being a “teenage trot”?

“This issue has nothing to do with law”

That point of view does make it quite hard to have an adult conversation about the proper application of tax law.

Says the person who acted like a child before. Trying to get back at me for that are you? I’m not trying to have any sort of conversation about the proper application of tax law – this is where you and Tim W are acting in a rather childish manner by insisting on talking about capitalism when UK Uncut’s issue with Philip Green is to do with morality.

“Does the precedent set by Cadbury Scweppes invalidate the UK Controlled Foreign Companies tax system?”

“It’s not fair!”

Pathetic. Utterly pathetic Tim. A lame straw man argument.

And what is this obsession of yours with CFCs? How about commenting about that paragraph from Private Eye that I have now quoted several times?

Generally people who feel they are making a strong argument don’t call people “twats”.

Way to go CJ, ignore pretty much everything I said in my previous post. Can’t you reply to it?

Firstly, what argument were you talking about before and what argument are you talking about now? Presumably you don’t actually know because otherwise you would have said.

Secondly, how is making a strong argument and calling someone a twat mutually exclusive? I imagine the reason you don’t see it that often is because most people don’t act in a truly obnoxious way like Tim W has been acting. As I said before, I think that calling Tim W a twat is perfectly justified in the circumstances.

Oh, and what is your real first name?

Oops, missed out this:

I receive dividends from many companies for which I do not work.
Is that immoral?
I pay no tax of many of those dividends as the shares are held in my pension plan.
Is that immoral?

Irrelevant! All I’ve been trying to do is get through to Tim W why UK Uncut have an issue with Philip Green.

*Asserting* immorality is not the same as *arguing* immorality.

Whatever.

And you do, as Luis has consistently pointed out, unfortunately have to worry about the *details* if you wish to make changes. You have to worry very much about the details.

Why? Why can’t others worry about the details? Why is it down to me or UK Uncut to work out the details?

We’re just going round and.round a moralistic argument with no legal backup to the points you’ve raised.

We haven’t gone round and round, we’ve only just to the position where Tim W stops being so utterly obsessed about capitalism.

And why does there need to be a legal backup? Since when did this thread become the country’s main debating area for this issue? Why not just leave the issue for now?

X is wrong.

OK – what do you suggest?

Oh, someone else can work that out.

matt,

I think some commentators are asking you to specify precisely what you think is immoral about what Green did. Can I take a stab at it?

it’s not that some people are rich, it’s not that dividends are not earnt, it’s not that foreigners are not taxed by the UK on dividend earnings …. it’s that Green was really the owner of Arcadia, and we want to tax the owners of capital on capital income, and we think that owners of capital ought to pay tax on capital income in some moral sense, just like the rest of us pay tax on our human capital income (wages), but he used the laws – that may be quite reasonable in their own right – to transfer ownership to his wife and avoid paying tax on that capital income that would otherwise have been due.*

In which case we have a happy coincidence of those with moral and those with pragmatic motivations – both of us would like to fix things so that maneuver is no longer possible.

* I am assuming that’s what he did. If his wife was independently wealthy and supplied the capital that created/acquired Arcadia herself, that that capital income was always hers and never Philip’s and the whole problem goes away.

You’ve done it again, you’ve ignored pretty much everything I said in my previous post! This is one lot of what I said before:

Way to go CJ, ignore pretty much everything I said in my previous post. Can’t you reply to it?

Firstly, what argument were you talking about before and what argument are you talking about now? Presumably you don’t actually know because otherwise you would have said.

Secondly, how is making a strong argument and calling someone a twat mutually exclusive? I imagine the reason you don’t see it that often is because most people don’t act in a truly obnoxious way like Tim W has been acting. As I said before, I think that calling Tim W a twat is perfectly justified in the circumstances.

Oh, and what is your real first name?

“X is wrong.

OK – what do you suggest?

Oh, someone else can work that out.”

Can you read? This is part of what I said in that post:
“Irrelevant! All I’ve been trying to do is get through to Tim W why UK Uncut have an issue with Philip Green.”

That’s all that I’ve wanted to do on this thread. And I’ve already written huge amounts in trying to do it. I haven’t been interested in extending the argument here. So yes, someone else can work out how the law should actually change to deal with people like Philip Green.

Perhaps I would have been interested in working out how a different system could work, but not now that I’ve had to write just so much to deal with Tim Worstall.

” I am assuming that’s what he did. If his wife was independently wealthy and supplied the capital that created/acquired Arcadia herself, that that capital income was always hers and never Philip’s and the whole problem goes away.”

At the time that Taveta aquired Arcadia, it was entirely in Tina Green’s name.

So, yes, this is a story of owner of capital getting paid for having hired a good manager to increase that capital…….

I’ve been looking back, trying to see just where this stupid long thread really got going, and it was post 16 by Tim Worstall where he said this:

All of the actual examples being used by UKuncut are simply horseshit.

People are welcome to argue about the practical issues surrounding Philip Green and his wife’s dividends, but UK Uncut’s issue in this case is that what happened was immoral. He could’ve paid the money to himself and paid the tax on that but instead he paid it to his wife, thereby avoiding £300 million in tax. You can disagree about the morality here but you can’t disagree with the fact that the immorality, as they see it, is why UK Uncut are targeting Green.

“He could’ve paid the money to himself and paid the tax on that but instead he paid it to his wife, thereby avoiding £300 million in tax. ”

No, he couldn’t have paid it to himself.

It was a dividend. Dividends are paid to shareholders. Phillip Green is not the shareholder. Tina Green is.

Tina Green could’ve given her shares to Philip Green. Or she could’ve publicly given that £300 million if not to HMRC then direct to the NHS to pay for midwives or nurses or doctors or if not the NHS then charities helping the poor, trying to cure cancer, whatever. She would still have received £900 million. It’s just pure greed.

“At the time that Taveta aquired Arcadia, it was entirely in Tina Green’s name.”

come on Tim, don’t piss about you know that only causes the question to regress to whether how she came to own Taveta. What matters is whether she stumped up the capital or whether Green gifted the capital to her to avoid paying tax on capital income. I am sure you are capable of keeping a grasp on the fundamentals if you try.

As far as I’m aware, it was a newly formed company. Costs a few hundred quid.

They borrowed the money, leveraged takeover I think…..

Matt,

I appreciate that error but my issue with those people is that they don’t normally suggest an alternative.

You seem to be holding ‘those people’ to a higher standard than you hold UK Uncut. Besides, those people have suggested alternative means of taxing, on many, many occasions.

Why can’t others worry about the details? Why is it down to me or UK Uncut to work out the details?

In my view, you’re the ones complaining so ‘morally’ you ought to make a stab at it. Why is it down to anyone else?