Global firms’ tax pay ‘an insult’













Global firms in the UK that pay little or no tax are an “insult” to British businesses, a committee of MPs says.












Public Accounts Committee chairwoman Margaret Hodge said HM Revenue and Customs (HMRC) needed to be “more aggressive and assertive in confronting corporate tax avoidance”.


Multinationals such as Starbucks and Amazon have come under fire for paying little or no tax.


They generate UK sales of hundreds of millions of pounds.


Starbucks, for example, sold nearly £400m worth of goods in the UK last year, but paid no corporation tax at all, because much of the money it earns in this country is transferred to a sister company in the Netherlands in the form of royalty payments.


HMRC said it already ensured that international companies paid the tax due “in accordance with UK tax law”.


UK-based companies pay corporation tax on their taxable profits wherever they are made. Companies based outside the UK must pay tax on profits made in this country.


Continue reading the main story

Multinationals in the tax spotlight


Starbucks’ UK sales last year were £400m but much of its earnings are paid as royalties to another part of the company.


Amazon generated sales of more than £3.3bn in the UK last year but paid no corporation tax on any of the profits, and is under investigation by the UK tax authorities, according to the Guardian newspaper.


Apple paid less than 2% corporation tax on its profits outside the US, paying $ 713m (£445m) on foreign pre-tax profits of $ 36.8bn.


Google’s UK unit paid £6m to the Treasury in 2011 on UK turnover of £395m, according to the Telegraph newspaper.


Source: Various



The influential committee’s report comes after it took evidence in November from executives from Starbucks, Google and Amazon about the amount of corporation tax the companies have paid in the UK.


‘Evasive evidence’


Margaret Hodge told the BBC that there was a danger corporation tax was becoming “voluntary” and that this had to change.


“These global companies are making money in the UK. All we are saying is that if you have economic activities in the UK you are making profits and tax is payable on that,” she said.


It emerged on Sunday that coffee shop chain Starbucks is in talks with HMRC about the amount of tax it pays.


Meanwhile, Chancellor George Osborne will unveil later details of £154m of funding to help tackle tax avoidance and evasion, amid public concern over the tax affairs of major international companies and wealthy individuals.


Continue reading the main story

Start Quote



Although they employ many thousands of people in Britain, it is unclear whether collectively they are net creators or destroyers of employment”



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The money will be used to take on extra staff to investigate high earners who aggressively avoid or evade paying tax and global firms that use legal loopholes to move profits out of the UK.


The funding is expected to help bring in about £2bn a year for HMRC.


In the report, Mrs Hodge said the level of tax taken from multinational firms with large UK operations was, “outrageous and an insult to British businesses and individuals who pay their fair share”.




Public Accounts Committee chairwoman Margaret Hodge: “It is time for HMRC to get a grip”.



“The inescapable conclusion is that multinationals are using structures and exploiting current tax legislation to move offshore profits that are clearly generated from economic activity in the UK.


“HMRC should be challenging this, but its response so far to these big businesses and their aggressive tax planning has lacked determination and looks way too lenient. Policing the tax system must be at the heart of what HMRC does.


An HMRC spokesman said: “We relentlessly challenge those that persist in avoiding tax and have recovered £29bn additional revenues from large businesses in the last six years, including £4.1bn in the last four years from transfer pricing enquiries alone.”


‘Breathtaking hypocrisy’


Continue reading the main story

Analysis




It is worth remembering that corporation tax is not the only tax that companies pay. Corporation tax does raise £50bn in the UK, but other taxes that cannot be avoided so easily include VAT; then there is the business rate, which raises some £25bn a year. The Institute for Economic Affairs says that is enough to pay for the secondary education system and the police and the fire service.


Also, companies pay National Insurance contributions for every worker they hire and fuel duty and vehicle excise duty which are one of the biggest revenue earners for the government.


That doesn’t mean that foreign companies aren’t doing their best to avoid paying corporation tax on the profits they make here, but then UK companies operating in France, China or the US are probably doing much the same there.


Laws on corporate taxation are extremely complex and often part of internationally negotiated treaties, one reason they are difficult to change and why companies have become very good at exploiting every legitimate and legal loophole that they can.



In a statement to coincide with the committee’s report, Amazon said it paid all applicable taxes in every jurisdiction that it operated in: “We have a single European headquarters in Luxembourg with hundreds of employees to manage this complex operation.”


Starbucks said in a statement: “We have listened to feedback from our customers and employees, and understand that to maintain and further build public trust we need to do more.


“As part of this we are looking at our tax approach in the UK. The company has been in discussions with HMRC for some time and is also in talks with the Treasury.”


‘Small fry’


The War on Want charity, which is campaigning for more to be done to tackle tax avoidance, accused the government of “breathtaking hypocrisy”.


It said: “Osborne and Cameron are happy to talk tough on tax. But, in reality, their plans will only go after the small fry on the fringes, while giving a green light to multinationals like Amazon, Google and Starbucks to continue avoiding billions in tax.”


Heather Self, a tax expert, told the BBC assessing tax for major companies was not simple.


“If you buy a book from Amazon you are actually buying from a Luxembourg company,” she said. “It decides how many books to buy and at what price they sell them for. All you have in the UK is a warehouse, a very big warehouse that employs a lot of people but that is all it does. The risk is taken in Luxembourg.


“Profits paid here are for the activities it undertakes here and that is not highly profitable. It is not as simple a situation as the Public Accounts Committee likes to make out sometimes.”


BBC News – Business


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Italy votes for center-left candidate for premier












ROME (AP) — Italians are choosing a center-left candidate for premier for elections early next year, an important primary runoff given the main party is ahead in the polls against a center-right camp in utter chaos over whether Silvio Berlusconi will run again.


Sunday’s runoff pits a veteran center-left leader, Pier Luigi Bersani, 61, against the 37-year-old mayor of Florence, Matteo Renzi, who has campaigned on an Obama-style “Let’s change Italy now” mantra.












Nearly all polls show Bersani winning the primary, after he won the first round of balloting Nov. 25 with 44.9 percent of the vote. Since he didn’t get an absolute majority, he was forced into a runoff with Renzi, who garnered 35.5 percent.


After battling all week to get more voters to the polling stations for round two, Renzi seemed almost resigned to a Bersani win by Sunday, saying he hoped that by Monday “we can all work together.”


Bersani, a former transport and industry minister, seemed confident of victory as well, joking about Berlusconi’s flip-flopping political ambitions by asking “What time did he say it?” when told that the media mogul had purportedly decided against running.


Next year’s general election will largely decide how and whether Italy continues on the path to financial health charted by Premier Mario Monti, appointed last year to save Italy from a Greek-style debt crisis.


The former European commissioner was named to head a technical government after international markets lost confidence in then-Premier Berlusconi’s ability to reign in Italy’s public debt and push through sorely needed structural reforms.


Berlusconi has largely stayed out of the public spotlight for the past year, but he returned with force in recent weeks, announcing he was thinking about running again, then changing his mind, then threatening to bring down Monti’s government, and most recently staying silent about his political plans.


His waffling has thrown his People of Freedom party into disarray and disrupted its own plans for a primary — all of which has only seemed to bolster the impression of order, stability and organization within the center-left camp.


A poll published Friday gave the Democratic Party 30 percent of the vote if the election were held now, compared with some 19.5 percent for the upstart populist movement of comic Beppe Grillo, and Berlusconi’s People of Freedom party in third with 14.3 percent. The poll, by the SWG firm for state-run RAI 3, surveyed 5,000 voting-age adults by telephone between Nov. 26 and 28. It had a margin of error of plus or minus 1.36 percentage points.


It’s quite a turnabout for Berlusconi’s once-dominant movement, and a similarly remarkable shift in fortunes for the Democratic Party, which had been in shambles for years, unable to capitalize on Berlusconi’s professional and personal failings while he was premier.


But Berlusconi’s 2011 downfall and a series of recent political party funding scandals that have targeted mostly center-right politicians have contributed to the party’s rise as Italy struggles through a grinding recession and near-record high unemployment.


Angelino Alfano, Berlusconi’s hand-picked political heir, seemed again exasperated Sunday after a long meeting with his patron over Berlusconi’s plans. News reports have suggested Berlusconi might split the party in two and re-launch the Forza Italia party that brought him to political power for the first time in 1994.


“We have to work to reconstruct the center-right, and reconstructing it means having a big center-right party,” not a divided one, Alfano said.


He added that Berlusconi didn’t say one way or another if he would run himself. “It’s his choice,” he said. “If there are any decisions in this regard, he’ll be the one to say so.”


___


Follow Nicole Winfield at www.twitter.com/nwinfield


Europe News Headlines – Yahoo! News


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Microsoft’s next-gen Xbox again said to launch ahead of 2013 holidays












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Lindsay Lohan risks return to jail after double trouble












NEW YORK/LOS ANGELES (Reuters) – Lindsay Lohan on Thursday faced the possibility of being sent back to jail after a tumultuous 24 hours in which she was arrested in New York for assault, and charged in California with reckless driving and lying to police over a June car crash.


Lohan, 26, who has been to rehab, jail and court multiple times since a 2007 arrest for drunk driving and cocaine possession, is still on unsupervised probation in Los Angeles for a 2011 jewelry theft.












But prosecutors in Santa Monica, California, said in a statement on Thursday that the “Mean Girls” actress lied to police when she told them she was not at the wheel of her Porsche when it smashed into a truck on a busy highway in the summer.


They charged Lohan with three misdemeanor counts stemming from that collision, hours after the troubled starlet was arrested on suspicion of punching a woman in the face at a Manhattan nightclub.


Lohan’s New York attorney Mark Heller said the actress was “a victim of someone trying to capture their 15 minutes of fame.”


“From my initial investigation, I am completely confident that this case will be concluded favorably and that Lindsay will be completely exonerated,” Heller said in a statement on the nightclub incident.


Frank Mateljan of the Los Angeles City Attorney‘s office, which handled the 2011 jewelry case, said prosecutors were still awaiting paperwork from New York and Santa Monica to determine if they will pursue a probation violation case against Lohan.


A Los Angeles judge told Lohan in March that she must obey all rules until 2014, and advised her to stop night-clubbing and focus on her work.


The two incidents came during a rough week for the former “Parent Trap” child star, who was once considered one of the most promising young actresses in Hollywood.


Her comeback performance on Sunday as screen legend Elizabeth Taylor in the TV movie “Liz & Dick,” was panned by critics and watched by a disappointingly small U.S. TV audience of 3.5 million.


In New York, Lohan was briefly arrested shortly after 4 a.m. (0900 GMT) on Thursday on a third-degree misdemeanor assault charge against a 28-year-old woman, police said. The victim suffered minor injuries, New York Police Sergeant John Buthorn said.


Celebrity website TMZ.com said Lohan had been drinking heavily and lashed out in a stand-off over one of the members of British boy band The Wanted, who were also at the club after playing a concert in New York.


Lohan’s recent visits to New York have featured run-ins with police and public spats over the last three months.


In October, police were called to the Long Island home of Lohan’s mother, Dina, after a loud argument, though no arrests were made. In September, Lohan was arrested in Manhattan after a pedestrian told police her car had struck him in an alley, but charges were not filed.


(Reporting by Colleen Jenkins in New York and Jill Serjeant in Los Angeles; Editing by Xavier Briand and Eric Walsh)


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Geithner predicts Republicans will accept higher tax rates












WASHINGTON (Reuters) – Treasury Secretary Timothy Geithner pressed Republicans to offer a plan to increase revenues and cut government spending, and predicted they would agree to raise tax rates on the wealthiest to secure a deal by year-end to avoid the “fiscal cliff.”


In a blitz of appearances on five Sunday morning talk shows, Geithner insisted that tax rates on the richest needed to go up in order to reach a deal, a step Republicans have so far resisted, and he dismissed much of the contentious rhetoric from last week as “political theater.”












“The only thing standing in the way of would be a refusal by Republicans to accept that rates are going to have to go up on the wealthiest Americans. And I don’t really see them doing that,” Geithner, who is leading the Obama administration‘s fiscal cliff negotiations, said on NBC’s “Meet the Press.”


The comments mark the latest round of high-stakes gamesmanship focusing on whether to extend the temporary tax cuts that originated under former President George W. Bush beyond their December 31 expiration date for all taxpayers, as Republicans want, or just for those with incomes under $ 250,000, as President Barack Obama and his fellow Democrats want.


Republicans, who control the House of Representatives but are the minority in the Senate, have expressed a willingness to raise revenues by taking steps such a limiting tax deductions, but they have largely held the line on increasing rates.


A handful of House Republicans expressed flexibility beyond that of their party leaders about considering an increase in tax rates for the wealthiest, as long as they are accompanied by significant spending cuts.


But most House Republicans refuse to back higher rates, preferring to raise revenue through tax reform.


“There’s not going to be an agreement without rates heading up,” Geithner said bluntly on CNN’s “State of the Union.”


The scheduled expiration of the Bush-era tax cuts and automatic reductions government spending set to take hold early next year would suck about $ 600 billion out of the economy and could spark a recession. The Obama administration and Congress are engaged in talks to avoid the fiscal cliff with a less-drastic plan to reduce U.S. budget deficits.


WHO SHOULD PAY?


Geithner’s Sunday interviews are part of a broader push to build public support for the Democrats’ position in the negotiations. Obama has made campaign-style appearances, including visiting a Pennsylvania toy factory on Friday where he portrayed Republicans as scrooges at Christmas time.


While breaking no new ground on the Obama administration’s position on Sunday, Geithner repeatedly urged Republicans to provide their own plan.


“They said they’re prepared to raise revenues but haven’t said how, or how much, or who should pay,” Geithner said on NBC.


In an interview with the Wall Street Journal on Friday, the Republican leader in the Senate, Mitch McConnell of Kentucky, asked Democrats to accept an increase in the Medicare eligibility age, impose higher Medicare premiums for the wealthy, and slow cost-of-living increases for Social Security.


At least one of those suggestions appears to have White House support. On CNN, Geithner said the administration‘s proposal included a modest rise in premiums for higher-income Medicare beneficiaries.


“What we can’t do is sit here trying to figure out what works for them,” Geithner said. “The ball really is with them now.”


The administration has said it is willing to find savings in the Medicare and Medicaid healthcare programs for the elderly and poor, but Geithner reiterated in an interview with ABC’s “This Week” that it would only be open to looking at changes in the Social Security retirement program outside of the context of a fiscal cliff deal.


(Reporting By Aruna Viswanatha; Editing by Eric Beech)


Seniors/Aging News Headlines – Yahoo! News


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Starbucks: We must do more on tax













Global coffee chain Starbucks has said it is in talks with HM Revenue and Customs and the Treasury over how much UK tax it pays.












It is one of several well-known firms that were criticised over the level of their corporation tax payments.


The firm admitted that it “needed to do more” in the UK on tax.


Meanwhile, Chancellor George Osborne has pledged more funds for the British authorities to tackle tax avoidance by multinationals.


He told the BBC that an announcement would be made on Monday about the ” extra investment in the part of the Inland Revenue that tackles tax avoidance by multinational companies”.


A Public Accounts Committee report on the topic of how much tax multinational firms pay in the UK is due on Monday.


In November the committee took evidence from executives from Starbucks, Google and Amazon over the amount of tax the companies have paid in the UK.


‘Competitive’


“We have listened to feedback from our customers and employees, and understand that to maintain and further build public trust we need to do more,” said a Starbucks statement.


“As part of this we are looking at our tax approach in the UK. The company has been in discussions with HMRC for some time and is also in talks with The Treasury.”


It said more details would be released later this week.


BBC business correspondent Theo Leggett said the coffee company reported sales of nearly £400m in the UK last year, but paid no corporation tax at all.


“Much of the money it earns in this country is transferred to a sister company in the Netherlands in the form of royalty payments, leaving the UK division to report regular annual losses,” he added.


Mr Osborne did not single out any firms while making his announcement on the Andrew Marr Show.


He also said that as well as his extra funding for the UK authorities, it was also necessary to work at an international level on the issue.


“It is actually Britain who has been working with Germany and France to get those rules on the international table,” he said.


But he also warned against “pricing Britain out of the world economy”, adding that “if we make our taxes less competitive that will just mean more companies stay out of Britain”.


Monday’s PAC report is expected to be critical of the current way in which multinational firms used UK tax legislation.


After last month’s hearings, PAC chair Margaret Hodge MP said: “One of our concerns is that the ability of global companies to choose where to they put their costs and their profits gives them an unfair tax advantage that damages UK-based businesses,”


BBC News – Business


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Cargo plane crashes in Brazzaville, 3 dead












BRAZZAVILLE, Republic of Congo (AP) — A cargo plane owned by a private company crashed Friday near the airport in Brazzaville, the capital of the Republic of Congo, killing at least three people, officials said.


The Soviet-made Ilyushin-76 belonged to Trans Air Congo and appeared to be transporting merchandise, not people, said an aviation official who requested anonymity because he was not authorized to speak to the media.












The plane was coming from Congo‘s second-largest city, Pointe Noire, and tried to land during heavy rain, he said.


Ambulances rushed to the scene in the Makazou neighborhood, located near the airport, but emergency workers were hampered by the lack of light in this capital, which like so many in Africa has a chronic shortage of electricity.


“At the moment, my team is having a hard time searching for survivors in order to find the victims of the crash because there is no light and also because of the rain,” Congolese Red Cross head Albert Mberi said.


He said that realistically, they will only be able to launch a proper search Saturday, when the sun comes up.


Reporters at the scene fought through a wall of smoke. Despite the darkness, they could make out the smoldering remains of the plane, including what looked like the left wing of the aircraft. A little bit further on, emergency workers identified the body of the plane’s Ukrainian pilot, and covered the corpse in a blanket.


Firefighters were trying to extinguish the blaze of a part of the plane that had fallen into a ravine. They were using their truck lights to try to illuminate the scene of the crash. Although the plane was carrying merchandise, emergency workers fear that there could be more people on board.


Because of the state of the road connecting Pointe Noire to Brazzaville, many traders prefer to fly the roughly 400 kilometers (250 miles).


Africa has some of the worst air safety records in the world. In June, a commercial jetliner crashed in Lagos, Nigeria, killing 153 people, just a few days after a cargo plane clipped a bus in neighboring Ghana, killing 10.


Africa News Headlines – Yahoo! News


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EBay’s double tax base prompts calls for investigation












LONDON (Reuters) – Britain and Germany may have missed out on a combined $ 1 billion in sales tax since online marketplace eBay picked a tiny Luxembourg office as its base for EU sales, a shift that lawmakers say should now be investigated.


EBay’s nomination of Luxembourg unit eBay Europe Sarl – with a staff of nine – as its provider of services to EU clients allows it to charge customers in Europe a low rate of sales tax, often known as Value Added Tax, helping it to compete against rivals.












However, the unit doesn’t actually receive the money from sales. Instead, eBay said it continues to channel revenues through a Berne-based unit, allowing the company also to benefit from what Swiss tax lawyers say is the most competitive corporate income tax regime in Europe.


EU rules allow companies to establish subsidiaries in Luxembourg and levy VAT at Luxembourg’s low VAT rate on sales to customers across the bloc.


However, the rules also allow individual EU taxmen to challenge any claim to Luxembourg residence, and the right to charge Luxembourg VAT, in their domestic courts, if the taxman feels a Luxembourg-based subsidiary does not have sufficient staff or assets to support its claim to be the true supplier of goods or services.


Tax experts say eBay’s arrangement, which appears to give eBay the best of both income and sales tax worlds, could be open to challenge, and lawmakers in the UK and Germany want their taxmen to investigate.


“I hope that HMRC (UK tax authority Her Majesty’s Revenue and Customs) takes note … and takes prompt action,” said Margaret Hodge, member of parliament and chairman of the Public Accounts Committee (PAC), which monitors government finances.


“I will be seeking assurance that they are, next time we take evidence from HMRC,” she added. Officials from HMRC are due to testify to the PAC in early December as part of the committee’s investigation into tax matters.


Sven Giegold, member of the European Parliament for Germany’s Green Party, said he wanted the German tax authorities to “have a very critical look at this”.


It is common for companies to seek to reduce their tax bills, and a number of multinationals have established bases in Luxembourg so they can charge customers lower levels of VAT.


EBay said HMRC was aware of all its tax arrangements and that it was confident it met all its tax liabilities in the UK and elsewhere.


“In all countries and at all times, eBay is fully compliant with national, EU and international tax rules (including the OECD) including the remittance of VAT to the appropriate authorities,” an eBay spokesman said in an emailed statement.


The UK, German, French and Luxembourg tax authorities declined to comment on eBay, citing rules on taxpayer confidentiality.


LOWER THRESHOLD


Big companies’ tax practices have risen to the top of the political agenda in Europe in the past year, with lawmakers growing increasingly frustrated with the way in which companies such as search engine company Google pay almost no income tax in countries where they have billions of dollars in sales.


The companies escape liability for income taxes in countries like the UK by arguing the value created by their business, and therefore the location where the profit should be realized, is not the place where the customer resides, but rather in the location where the intellectual property underpinning the product or service is based.


Chas Roy-Chowdhury, head of taxation at the Association of Chartered Certified Accountants, said this was a valid economic argument and that if, for example, HMRC wants to claim more income tax from Google, it has to prove the company is generating more value in the UK than it is declaring.


This would require a thorough deconstruction of its business model and supply chain.


However, it is easier to establish liability to VAT, since this tax hinges simply on the location of the buyer and seller.


“The threshold is lower,” said Simon Newark, head of VAT at accountants UHY Hacker.


“There are a lot more aspects for HMRC to challenge in VAT than in direct (income) tax.”


For tax purposes, the EU deems eBay’s online platform an “electronically supplied service”, a category that also covers e-Books and music downloads.


Under EU rules, suppliers of such services based within the bloc are supposed to charge EU customers VAT at the rate prevailing in the country where the supplier is based.


A number of suppliers of electronic services, including Amazon.Com Inc and Apple Inc’s iTunes have established European headquarters in Luxembourg to enable them to charge customers lower VAT rates than prevail in their customers’ countries.


Luxembourg has traditionally charged the lowest standard VAT rates in the European Union. Its 15 percent rate compares with rates of 19-25 percent in most other EU members.


By charging customers VAT at Luxembourg’s rate eBay is better able to compete with rivals based elsewhere in the EU, such as Britain’s eBid, which must charge customers VAT at the standard UK rate of 20 percent.


However, to be entitled to charge Luxembourg rates, a company has to be able to prove in British, German or EU courts that it is genuinely based in the Grand Duchy.


Companies selling to EU customers from outside the EU – as eBay was until the 2007 nomination of eBay Europe Sarl as supplier to EU clients – must charge European customers VAT at the rate prevailing in the country where the customer resides, and to pay that VAT to the taxman in the customer’s country.


There is no definitive checklist that determines the true base of a company and any decision by a national court can be challenged in the European Court of Justice. In the UK, HMRC said it approached the matter on a case-by-case basis, and disputes are often resolved in court.


“HMRC will challenge any arrangements where it is claimed that supplies are made from a particular country but the business does not have the necessary resources to make those supplies,” a spokesman said.


EUROPE EXPANSION


EBay, which is headquartered in San Jose, California, moved into Europe in 1999 when it established eBay International in Berne. Switzerland’s low income tax regime for foreign companies was highly beneficial for the auction site. “We do have a very favorable international tax structure,” then-Chief Financial Officer Rajiv Dutta told analysts in 2002 when asked how the company managed to pay such low taxes on its non-U.S. income.


The Swiss base also meant, initially, that the company didn’t have to charge EU customers VAT. But in 2003, Brussels changed the rules, which forced eBay to charge EU sellers on its platform VAT based on their residence. The VAT gathered was remitted to the tax authority in the customer’s country.


Not all customers are charged VAT. Most medium-sized and big businesses are legitimately exempted from paying VAT on some purchases, such as eBay seller fees.


EBay’s Swiss-based European public relations head declined to say what portion of its EU customers were liable to be charged VAT. James Cordwell, equities analyst at Atlantic Equities, estimated that such customers accounted for 40-50 percent of sales in Europe.


Since the 2007 creation of its Luxembourg operation, eBay has had German fee revenues of $ 6.1 billion and UK revenues of $ 5 billion, its annual accounts show.


If the services were supplied from Switzerland or another non-EU country, and assuming only half of customers should have been charged VAT, EU rules would have obliged eBay to collect $ 580 million in VAT for the German taxman and $ 500 million in VAT for HMRC since 2007.


EBay’s entitlement to charge Luxembourg VAT on sales and to pay this to the Luxembourg taxman rests on being able to prove in court that eBay Europe Sarl is the provider of services to EU clients.


But despite German and UK fee income of $ 3.1 billion last year, eBay Europe Sarl recorded turnover of only 5 million euros in 2011.


John Hemming, an MP with the Liberal Democrats, the junior partner in the British coalition government, said the fact eBay’s sales revenues did not go through the Luxembourg unit undermined the claim that it was the true provider of services to EU clients.


“If it’s a real transaction, you would expect the money to pass with it, and not pass someplace else,” he said.


Rather than going to Luxembourg, the money generated from customers continues to go to Berne-based eBay International AG, a spokeswoman said.


When Reuters visited in mid November, staff at the Luxembourg office, just opposite the central post office, declined to discuss what operations the unit conducted for eBay.


A spokesman later said the office conducted activities including billing, data privacy, contracting, regulatory, management and some customer services operations.


By contrast, Amazon and iTunes do report their sales of ebooks and music downloads to EU customers through their Luxembourg units.


Prem Sikka, professor of accounting at Essex University, along with Newark and Roy-Chowdhury said a cash trail through a unit was one of the key factors used as evidence that the unit was the true supplier of a service.


UK and German tax authorities could argue that the shift in eBay’s supply base to Luxembourg from Berne was therefore not genuine. If successful, they could claim back the VAT lost.


EBay declined to say why it channeled sales through Switzerland. Tax advisors say the country can still offer some companies lower tax rates than other European low-tax jurisdictions such as Ireland and Luxembourg.


Indeed, EBay’s closest rival Amazon, which channels about half its non-U.S. earnings through Luxembourg, reported average income tax on overseas earnings of 6 percent in the past four years. EBay paid just 3 percent over the same period.


(Additional reporting by Brenda Goh; Editing by Will Waterman)


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Katie Holmes in “Dead Accounts”: what did the critics think?












LOS ANGELES (TheWrap.com) – With her marriage to Tom Cruise firmly ensconced in the rearview mirror, Katie Holmes has returned to Broadway to star in Theresa Rebeck‘s “Dead Accounts.”


But the “Dawson’s Creek” actress who will forever be synonymous with one mega-star’s epic Oprah freakout, got credit from many critics for giving it the proverbial college try – although most reviewers savaged the production.












Dead Accounts” centers on a hotshot Wall Street-type (Norbert Leo Butz) who returns to his Cincinnati home with a dark secret. Holmes plays his sister who is still living at home and nursing their father through a kidney stones attack. It marks her second appearance on the Great White Way after a tepidly received turn in a 2008 revival of Arthur Miller‘s “All My Sons.”


Dead Accounts,” which also stars Josh Hamilton and Jane Houdyshell, premiered Thursday at the Music Box Theatre.


In the New York Times, Ben Brantley was surprisingly gentle in his treatment of Holmes even as he dripped acid over Rebeck’s attempt to say something profound about America’s post-Recession doldrums.


“Let me assure you that Ms. Holmes, who was a tad unsteady in her Broadway debut four years ago in Arthur Miller‘s ‘All My Sons,’ appears much more at ease playing a worn-down country mouse to the hyped-up city mouse of Mr. Butz,” he wrote. “Gamely unkempt and lumpen, Ms. Holmes suggests what might have happened to Joey Potter, the ultimate girl-next-door she once portrayed on TV in ‘Dawson’s Creek,’ had she never found true love or left town.”


His overall assessment of the action onstage was far more dire, faulting it for devolving “…into a limp chain of anticlimaxes.”


Also declaring “Dead Accounts” D.O.A. was New York magazine, which, in an unbylined piece, compared Rebeck to Tyler Perry for white people (sorry, “Madea Goes to Jail” fans, it’s not a compliment). However the critic was charitable in assessing the third Mrs. Cruise.


“Holmes is insanely miscast but sunnily game in the role of a ground-down never-was with body image issues and a crater where her confidence should be,” the reviewer wrote.


Those relatively benign notices aside, some critics were clearly sharpening the kitchen-ware for Holmes. In the New York Post, Elisabeth Vincentelli took a cleaver to the actress and the play.


“She’s got one note – shrill, impatient – and yells it at top volume, making a vein bulge on her slender neck. (A recurring joke about Lorna going on a diet falls flat.),” Vincentelli wrote.


Of the play, the Post critic said it should be back to the drawing board; “With its cardboard characters and implausible developments, ‘Dead Accounts‘ feels like a rough first draft.”


Chris Jones of the Chicago Tribune was far kinder when it came to Rebeck’s writing, admiring her for taking on weighty topics, even as he complained she often fell flat in her execution. His views on Holmes were harder to decipher. Though never pejorative, Jones seemed to feel that Holmes’ tabloid past interfered with her stage work.


Still, he was intrigued by the way her own Midwestern background intermingled with that of her character.


“‘Dead Accounts’ hints at the very worthwhile notion that two Americas have grown up alongside each other, one in the thrall of religion, the other of money,” Jones wrote. “Holmes, one suspects, knows a good deal more about that kind of stuff than her character ever gets to say here.”


People Magazine’s Tom Gliatto praised Holmes’ for doing what she could with an underwritten role. He didn’t exactly make her seem Tony bound, but he argued that the fault rests more with the script than the actress.


“Holmes gets her moments in the second act: Lorna is given a simple, tender monologue about planting a tree when she was a child, followed by a full-throttle, over-the-top tirade against money, banks and fiduciary wickedness,” Gliatto wrote. “Holmes gets a big laugh there, but you have the nagging realization that the little memory about the tree slipped by without registering emotionally – that it was a lot more meaningful than the tirade, and that Holmes should have been directed to dig deeper. Or that Rebeck, creator of NBC’s Smash, should have written deeper.”


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Top 10 Rules for a Flat Belly












For all the effort you’ve put into toning it–and for all the cupcakes you’ve given up to maintain it–your midsection should be as rock-hard as a diamond and just as much fun to show off. So why does it seem like your quest for a sexy stomach always hits a bump…right about belly-button level?


You’re not alone in feeling frustrated: Sixty-two percent of women say the body part they’re most self-conscious about is their belly. But don’t give up hope–just change your thinking. Turns out, some of the old food advice you’ve been following for years may actually be working against you, says Alan Aragon, a nutritionist in Westlake Village, California. The latest research is full of new culinary strategies for shrinking your stomach (and slimming down all over). After wading through the data to answer your most common questions, Aragon presents his core counsel.












The No-Crunch Ab Workout


Will eating smaller meals curb my hunger?


Contrary to what you’ve heard, the five-small-meals-a-day mantra doesn’t work for everyone. The new thinking? You’ll eat healthiest if you eat your way–meaning, if you prefer substantial meals fewer times a day, there’s no reason to force yourself to do the opposite, says Aragon. But while the number of meals doesn’t matter, their size does.


According to Purdue University researchers, the biggest problem with our noshing behavior is that snacks have become meals, and meals have become feasts. In the past 30 years, snack sizes have increased from 360 calories to a whopping 580! When you consider that the average woman snacks twice during each workday, you’re looking at almost 500 extra calories a day. In just two weeks, these oversize bites–no matter how “healthy” they are–can contribute to an extra pound of fat. The takeaway: However many times you eat, always make sure that you’re keeping an eye on your portions.


7 Ways to Stop Food Cravings


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Health News Headlines – Yahoo! News


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