tag:blogger.com,1999:blog-4900303239154048192.post7803122907618013571..comments2024-03-06T06:34:42.881-05:00Comments on EconoSpeak: Ikea Transfer Pricing: The EU Green Party v. Tim WorstallUnknownnoreply@blogger.comBlogger6125tag:blogger.com,1999:blog-4900303239154048192.post-28247081320914033952017-01-21T04:18:33.662-05:002017-01-21T04:18:33.662-05:00Learn from the abject failure of the Greek elector...<i>Learn from the abject failure of the Greek electoral left.</i><br /><br />There is an important lesson to learn there, but it is simpler. Do not snatch defeat out of the jaws of victory. Tsipras & Syriza had won. They had the Greek people solidly behind them. Their strategy succeeded, with the best possible outcome - a negotiated Grexit. The "enemy" (who really wasn't an enemy) having shot its wad, was surrendering. <br /><br />Tsipras, overcome by mindless despair at the prospect of having to behave like a responsible adult, rejected victory and ended up signing an infantilizing plan that was worse than the ones that Schauble, misguided but honest and thus maligned, had told Varoufakis after offering them, that he would not accept if he were in Varoufakis's shoes.<br /><br />As Bobby Fischer said: "You don't win games by resigning." Calgacushttps://www.blogger.com/profile/06031818010224747000noreply@blogger.comtag:blogger.com,1999:blog-4900303239154048192.post-11612295878988251552017-01-08T13:03:29.812-05:002017-01-08T13:03:29.812-05:00Say we start with a "Trade mark " donat...Say we start with a "Trade mark " donation to this tax empt outfit <br /><br />probably created a tax deductible event for the donor entity <br /><br />Here is an admittedly very specious basis for valuing the trade mark <br />But a start at any rate <br /><br />These appraisal events are great fun for clever elves <br /><br />Once again we see the futility of tax chasers <br />Yes it's a class struggle front<br />But not a very promising one long term <br />Even victories are temporary <br />Much like regulation. <br />But with far less short run clout Owen Painehttps://www.blogger.com/profile/13675803406994867138noreply@blogger.comtag:blogger.com,1999:blog-4900303239154048192.post-15905121580878344822017-01-08T12:40:43.335-05:002017-01-08T12:40:43.335-05:00Pgl really ought to stick to this beat
Here he ha...Pgl really ought to stick to this beat<br /><br />Here he has a fairly useful grasp of the game <br /><br />I note<br />He asks a key question<br />What did the tax exempt foundation pay for the trade mark <br /><br />3% of revenue is itself hardly generalizable <br /><br />Value added varies hugely from firm and industry to firm and industry <br /><br />Operating net margins vary similarly <br /><br />Starbucks is not owned by a foundation and it's franchisees <br />Qualify as " arms length " only because that term of art here<br />Operates like a hugely elastic O ring <br /><br />A nation state that does not tacitly conduct a full out cold . War on MNCs <br />Faces defeat <br />The courts are a class against class " corporate tilted " battlefield <br />not halls of justice <br /><br />Take administrative action <br /><br />Learn from the abject failure of the Greek electoral left <br /><br />Make macro navigation independent of MNC actions <br /><br /><br /> Unknowns rational surrender <br />to the enemy of society aka multi national limited liability corporations <br />Is understandable <br />Guys like pgl are chasing a rhino with a nose clipper <br />Quixotic would be too generous a characterization <br />Owen Painehttps://www.blogger.com/profile/13675803406994867138noreply@blogger.comtag:blogger.com,1999:blog-4900303239154048192.post-56055947443936401882017-01-08T09:29:54.164-05:002017-01-08T09:29:54.164-05:00At its base, is this not just another example of w...At its base, is this not just another example of why it is vain to tax the income of "businesses?" Income (or better still, consumption) of owners should be taxed. Of course this does not mean that all sorts of rules would not be needed to prevent income to owners from being disguised as expenses. Unknownhttps://www.blogger.com/profile/04661459590343267145noreply@blogger.comtag:blogger.com,1999:blog-4900303239154048192.post-4273815992800306082017-01-08T06:08:28.658-05:002017-01-08T06:08:28.658-05:00Tim - two points here. The 4% is a negotiated sett...Tim - two points here. The 4% is a negotiated settlement with a tax authority. A poor choice for a measure of market rates. Rather it is the 6% rate Starbucks charges independent entities. This is basic transfer pricing.<br /><br />Also basic transfer pricing - Starbucks is an entirely different business than Ikea with a higher profit potential. So even to even consider the Starbucks entire suite of intangibles as a comparable to the tradename for Ikea is another poor choice for evaluating that the 3% is consistent with arm's length.<br /><br />Maybe I was not as explicit as I should have been. But your attempt to justify the 3% as arm's length falls horribly short.ProGrowthLiberalhttps://www.blogger.com/profile/17138489390594441753noreply@blogger.comtag:blogger.com,1999:blog-4900303239154048192.post-78692639663623586762017-01-08T05:54:17.733-05:002017-01-08T05:54:17.733-05:00That Belgian law has been found to be state aid by...That Belgian law has been found to be state aid by the EU Commission already and needs to be reversed. I've covered that before.<br /><br />Re the 4% Starbucks. HMRC had a look at what Starbucks was charging itself and demurred at that 6% number. Insisted it be reduced to the 4%, which is where that number comes from.<br /><br />Thus a 3% Ikea royalty rate just doesn't look that far out of line at all.Tim Worstallhttps://www.blogger.com/profile/13161727860817121071noreply@blogger.com