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You support the recovery of Facebook and Google's "reasonable tax" it?

via:博客园     time:2016/8/9 10:30:40     readed:1747

Facebook recently mixed: just released second-quarter revenue growth of 59% over last year, net profit of up to $ 2.055 billion (about 13.6 billion yuan), compared with an increase of up to 186% over the same period last year; however, it again because tax arrears problems being targeted IRS (IRS) investigation, eventually paid a fine could be as high 30-5000000000 US dollars.

In the United States, the tax is simply paramount also extremely troublesome thing. Statistics tax, tax, tax rebates and other administrative reporting process very cumbersome, but if a leak taxes, the IRS once found, directly recorded in the individual's record of integrity in, and with China's & ldquo; Profile & rdquo; A bit like. If you go online to search to find news like this: immigration passport was canceled due taxes, student taxes were detained because they had been found to lead to taxes or mayor, Mr resignation, etc & hellip; & hellip;

For companies, especially big companies, and stars, which every move on the tax, no IRS is not the focus of & ldquo; care & rdquo; object. With the American people, these out-of American companies, but also struggle with the IRS for a lifetime. This time, the IRS once again pegged Facebook, it recovered to as high as 30-50 billion dollars in taxes and penalties & mdash; & mdash; you escape taxes we all know.

But & hellip; & hellip; people are legitimate tax avoidance friends.

In fact, whether Facebook, or Google and Apple, as well as you can imagine almost all major technology companies, many countries in the world are more or less & ldquo; less & rdquo; the tax. They rely on tax avoidance, nothing less than the three samples & ldquo; magic & rdquo ;. Not only easy to use, and legal & hellip; & hellip;

Put it into an Irish company

Facebook is a US company, Apple is a US company, Google is a US company, almost without a doubt. They are headquartered in California, from San Francisco to Silicon Valley in San Jose between, is a true American company & mdash; & mdash; in fact, legally, they are Irish companies & hellip; & hellip; because the tax rate is significantly lower than the United States, Ireland popular Headquarters US-based companies are favored, it is the world's most famous & ldquo; tax havens & rdquo; (tax heaven) one.

Tax havens:

Those to attract foreign capital inflows, the region's economic prosperity in the country or in the country or region to determine a range to allow people from abroad to invest and engage in various economic, trade and service activities in this, obtaining income or own property without their levy direct taxes, or implement a low direct tax rates, or the implementation of special tax incentives countries and regions.

In addition to Ireland, the world still in Panama, the Cayman Islands, Hong Kong, Luxembourg, Switzerland, Liechtenstein, US total more than fifty Virgin Islands and other tax havens.

Want legitimate tax avoidance? The first step is the establishment of corporate entities in these tax havens. Why do not we come a fictional case:

Stanford seniors Mark with a business plan to get venture capital, he dropped out of school and founded a technology company & ldquo; Alpha Power & rdquo ;, sales package to users of solar power solutions. Operation for some time, Alpha Power very substantial income, profits also good, the US government asked Alpha Power 35% of taxable profits. Mark screenwriters: 35% ah! Fast half! Not as good as stealing money OK?

He read law at Stanford classmate Linda gave him means a clear way & mdash; & mdash; why not go to the Irish registered company?

It turned out that under US law, registered in the US corporate tax rate is 35%, and if registered in Ireland, the tax rate is only 12.5%. If the Mark of the corporate entity, such as his office, secretary and hardware and software engineers and factories to stay in the United States, but the company registration to Ireland, immediate savings equal to 22.5% of the profits.

He said that at that moment, Mark has sent the secretary to take the next plane to Ireland registered a shell company, with the acquisition of Alpha Power, and finally completed the administrative process of registration in Ireland.

! Get registered offshore net income: 65% & rarr; 87.5%


Everything has just begun.

Then the subject of transfer pricing

US headquarters Mark sits drinking coffee and blowing air conditioning, good uncomfortable. A phone call, turned out to be the Australian branch sales representative Jack: boss, Australian business roar ah, here is the tax is too high! Not search do not know a check startle: Australian corporate income tax up to 30%, which means better sales in Australia, I lose out to the more tax money, you might as well do business.

Lawyer Linda once again came before him: Why not set up a company in Singapore, and then use transfer pricing to tax it?

Transfer Pricing:

Generally refers to large enterprise groups, especially multinational companies,The use of different tax rates in different parts of the enterprise as well as differences in tax exemption, the transfer of profits to low-tax or tax-exempt subsidiariesRealize the whole group of tax minimization. The enterprise group tend to lower prices in high-tax areas, and the high prices at the lower tax rate place.

It turned out that the same corporate income tax, Singapore received only 2.5%. If Mark setting up a company in Singapore, close to Singapore and then let the Australian market to the final purchase price of the user to the Australian company to sell mobile phone shell. To do so, the transfer of profits from high-tax to withstand Australian company to a low tax Singapore company to achieve the company's overall tax Alpha Power is minimized.

Specifically, how the tax savings it? We assume Alpha Power each product costs $ 50, shipped to Australia will be sold out:

1) If the US factory direct shipping 100 sets of products to the Australian company APAU, by the latter in the market by selling $ 100 each, the main profit is APAU, required to pay 30% tax, final Alpha Power earn money only 2000 Australian dollar.

2) If Mark Singapore APSG control from US plants at cost price of the acquisition of 100 sets, and then press the $ 100 price sold APAU, profit body becomes APSG, pay only 2.5 percent of the tax, the equivalent of Alpha Power She earned a 4750 Australian dollars.

Transfer Pricing Get Net income 87.5% & rarr;! 97.5%


In fact, almost friends with money laundering & hellip; & hellip;

And then finally the transfer of debt

This is actually the easiest, most people listening to blurt out: This is the line?

Linda gave Mark a big help, they gradually talk about anything. Finally one day, Linda to Mark describes the ultimate tax big kill: Luxembourg Holdings.

Alpha Power set up a holding company in Luxembourg AP Holding, Mark APAU control AP Holding to put 10,000 Australian dollars 50% interest usury, then let APAU AP Holding on the same day to repay the principal plus high interest.

Interest here is, in fact, APAU revenue. APAU it to earn money before tax debt will be transferred by way of the basic tax rate of zero AP Holding. This avoidance method, called the transfer of debt.

Debt Transfer:

Nothing to explain, international rules are debt interest can be deducted (tax-deductible).


(Here should have: This is also the line?)

Get net debt transferred 97.5% & rarr;! 100%


Our fictional Alpha Power, under the premise of using the perfectly legitimate these three magic completed avoidance. In reality, people worship Facebook, Google and Apple and other technology companies, is using these methods, one or several, avoiding hundreds of millions or even billions of dollars in tax scale.

Such as Google, the 2007 to 2009 tax method is this:


Images from almost know

Google at the time of the Australian Tax also uses Singapore as the previously mentioned tax havens: 2014 Australia Google revenue up to 20 billion Australian dollars, but only in Australia and Singapore, respectively, to pay A $ 11.7 million and $ 5 million equivalent taxes,Avoid the tax liability of 97%.

Facebook also use the Irish offshore registration and transfer of debt, etc., profits transferred to another tax haven of the Cayman Islands. In 2014, the British government on tax running Facebook advertising budget of about 2.7 million pounds in the same year, Facebook UK made 105 million pounds of revenue, butPay only £ 4327& Hellip; & hellip;

Of course, compared with Apple, Facebook and Google or unambitious. Apple Australia 2015 sales of $ 7.9 billion Australian dollars, only $ 85 million of income tax paid, a little more than 1%.


This figure shows the use of technology companies in the 2014 Singapore tax of each level

After reading so much, we need to again clear: above all fiction and reality avoidance methods, and events are perfectly legal under the premise of.

But this leads to the relevant tax & ldquo; the justice of & rdquo; discussed more and more. In the United States, for example, half of the revenue from personal income tax, and the remaining three percent from social insurance, corporate taxes contributed even less than a Chengdu.

In such a situation, the tax department whether it is necessary to recover the tax in the name of which they are imposed from technology companies & ldquo; attempt & rdquo; that part is still very controversial. Technologies for the huge R & D investment, bring all sorts of forms of scientific and technological innovation, improve infrastructure, enhance the people's welfare. Google neural network brought a strong computing power, Facebook shortened the distance between people, Uber, Airbnb bit and make high-quality travel and living easy and affordable, while the iPhone and Android smartphones to ensure that the All of these innovations can allow people to easily enjoy.

Technology industry, people in R & D investment accounted for the proportion of income to evaluate the innovative principles of a company, is not unreasonable. Technology companies to put more money into research and development in order to provide better services and products to ensure its leading position and innovative power. Every penny legitimate means of tax avoidance savings, and finally into a faster wireless network, clearer mobile phone camera, smarter AI, and you will be faster to a destination of each car.

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