Re: Greece - Rise of the left or rise of the young? : Fri Jan 30, 2015 8:15 pm
Ferocious Aardvark wrote:
Maybe, but I really don't see why HMRC don't just look at the profits in the accounts, and land them with a whopping great tax bill, on the basis if they want to enter into artificial schemes involving associated companies based in an attic in Luxembourg then that's fine, but does not affect their tax. They would have to pay that tax, and if they wanted to appeal through the courts and persuade a judge that it really was all genuine, and not at all an associated companies scam for no purpose other than to save tax, well, crack on, and good luck with that.
I agree.
It can't be beyond the wit of even HMRC to know that the price Starbucks UK pay Starbucks Geneva for coffee is vastly inflated. HMRC are great at assuming a level of profit with SMEs, there's not reason similar assumptions cannot be transferred to larger enterprises.
Similarly, if they look a little closer at Walkers Crisps, they may find even more opacity in accounting. From 1948, when Walkers first started frying, they have paid UK Corporation Tax on their profits, until the takeover by Pepsico in 1999. Walkers still buy their potatoes from British growers, they even source their flavourings from British sources too. Unfortunately this once profitable company no longer generates profit from its UK operations.
Now one could assume that the usually shrewd Pepsico got it's acquisition strategy spectacularly wrong with Walkers, alternatively one may think that even though the potatoes are still grown by the same farmers and trucked to the same factories, the fact that they are bought by Pepsico in Switzerland and then sold on to Walkers UK, may give some clue about transfer pricing. Alternatively, I suppose Pepsico may have seen the plight of potato farmers in the UK and decided they would pay way over market price for the best spuds.
Either way, the UK exchequer is being robbed blind