страны ЕС замахнулись на основу ирландской экономики

[Anatoli]

страны ЕС замахнулись на основу ирландской экономики (12,5 % налог на прибыль международных корпораций):

Today's Sunday Time's article "EU tax change to hurt Ireland" describes how a group of 10 EU states,including France,Germany,Italy and Spain,plans to tax multinationals based on their share of sales in the individual countries. If an Irish based multinational company had,say, 40% of its EU wide sales in Germany,then 40% of its EU wide taxable profits would be taxed in Germany at the ten country group rate of 25%. At present, the profits are taxable in Ireland only, at the low Irish rate of 12.5%.

While this move to higher country taxes will seem fair to some,it will reduce inward international investment to the EU and the tax regime in the EU will be more complicated. Thanks to excessive taxation for the funding of bloated welfare states,the EU's major states are already unattractive places to invest for many companies.

The argument of Irish government officials that the ability of multinationals based in Ireland to keep their corporate taxes low while investing in these ten countries helps the ten's international competitiveness, has fallen on deaf ears.

The ten country tax regime will also distort investment decisions in many ways:

[]The tax rate of 25% in the group of ten will drive multinationals' investment into large EU countries in Eastern Europe with lower tax rates in the long run,though the small tax haven countries like Ireland and Estonia will lose out.

[]Where the investment in facilities must be geographically close to the market of a country in the group of ten,say Germany,whenever possible the investment will be made in another country outside the group but close to Germany's border,say Poland.

[]If the products or services must be produced and delivered within the border of a country in the group of ten,the economics of combining low and high profit margin products will be undermined. Say the sale of a unit of product A had a pretax margin of 20% and of product B a pretax margin of 5%, the corporate tax on both which is based on sales would be the same. However,an economically efficient tax would result in a tax on A of four times that of B,recognising the difference in margins. This will incentivise companies to avoid investing in low margin businesses in the group of ten.

[]To correct for this disincentive, the group of ten could attempt to apply the tax in proportion to assets as well as sales. Would they choose total assets,total assets less non-interest current liabilities,shareholder equity or some other definition of assets? Having settled on a definition of assets, the group of ten would have to cope with the ingenuity of tax advisers and investment bankers in minimising the multinationals' assets bases within the group of ten. This could mean the fastest possible writeoff of assets,artificial inflation in non-interest current liabilities,excessive financial leverage used to minimise shareholders equity, keeping working capital outside the border of the group of ten,use of financial derivatives etc

[]Other tax avoidance schemes could be used to minimise the sales recorded in the group of ten.For example,a multinational selling to a German company could complete the sale to a subsidiary of the German company set up in Poland, with the German subsidiary shipping the product to its parent in Germany. Intercompany sales between parent and subsidiary are not counted in consolidated group accounts This scheme assumes the cooperation of the customer,which could be obtained with supplier price discounts.Alternatively, a multinational could use franchisees who could provide the goods or services on behalf of the multinatiional in Germany,which would receive its profits in franchise fees,or it could sell to agencies outside Germany who also operate within Germany.

The group of ten need to recognise that in a globalised world,it is very hard to beat markets.Their tax grab on corporate profits threatens to kill the goose that lays the golden egg-multinational investment.

They should recognise that corporate tax is just a drop in the bucket compared to all the other tax generated by business. Corporate tax of about 1% of sales is small compared to VAT,employer rates on property,employer payroll tax,employee payroll tax,not to mention the multiplier effects of investment.