スペインでにアメリカ合衆国の情報技術企業のApple,Google,Amazon,Facebook,eBay,Microsoft,Yahoo 会社は、売上や利益を税金のやすいアイルランド(法人税)やルクセンブルグなどに移転し、脱税。(スペインの大企業の法人税は30%)
Los siete gigantes de Internet pagan en España solo un millón en impuestos
Las filiales de Apple, Google, Amazon, Facebook, eBay, Microsoft y Yahoo trasladan el grueso de su facturación a otros países en los que la tributación es más baja
Las firmas defienden que cumplen con la legislación fiscal
In English: Tech giants taunt the taxman
Miguel Jiménez Madrid 18 ENE 2014 - 20:04 CET
Internet giants Seven charged in Spain only a million in taxes
Subsidiaries of Apple, Google, Amazon, Facebook, eBay, Microsoft and Yahoo moved the bulk of its sales to other countries where taxation is lower
The firms argue that comply with the tax laws
In Inglés: Tech giants taunt the taxman
Miguel Jiménez Madrid 18 ENE 2014 - 20:04 CET
The major U.S. technology groups continue to give the slip to the Spanish Treasury. Engineering tactics designed for their tax advisors allow only taxed in Spain by the business generated in the country. Spain 's main subsidiaries in seven major telcos ( Google , Apple , Amazon , Facebook, Yahoo , eBay and Microsoft ) show that the joint provision for income taxes for the year 2012 (the last of which have made their accounts) just added 1,251,608 euros. One million seven giants.
The aggregate hides actually figure that there are companies that paid taxes while other tax credit or tax offset future losses were noted after declaring . The figures do not come from their statements of Finance but the annual accounts of the subsidiaries , filed with the Companies Registry. These accounting items , which may differ somewhat from the tax assessments in a given prepayments , timing of temporary differences and other tax year. But these are the items destined Spanish subsidiaries in a particular income tax year . The last of the companies to deposit their Facebook accounts was Spain . He did it in December, but their accounts were not available electronically until Thursday , when COUNTRY expressly requested the Commercial Registry and because of that were scanned .
They try to move the bulk of its sales to other countries where taxation is lower
These have a lower box in which a system whereby those big technology groups try to move the bulk of its turnover is imposed ( or when it is not possible, your benefit ) to other countries where taxation is completed such as Ireland or Luxembourg. In addition , complex tax structures allow profits taxed not only in those countries. Google the bulk of its benefits is carried outside the United States to Bermuda without spending almost box. Apple , meanwhile , found as a U.S. senator called the Holy Grail of tax evasion. It has subsidiaries in accordance with U.S. law, not taxed in the U.S. because its headquarters is in Ireland , according to Irish law , is not taxable in Ireland that are managed and controlled from the United States. They have no tax country and therefore do not pay taxes anywhere.
The firms argue that scrupulously comply with the tax laws . The OECD and G20 try to plug the loopholes through which these companies are strained . For now, the battle to achieve pay taxes commensurate with the benefits generated in each country , companies win by a landslide .
moreApple uses no tax country subsidiariesGoogle , Apple and Microsoft pay minimal taxes outside the U.S.Tech giants , dwarves tax
Finance has launched in Spain against tax proclamations large multinational engineering and has created a specialized group as taxation, which has achieved some results in traditional multinationals. But Google Finance inspected and found only minor discrepancies in his statement. Thus its tax model was validated and with it that of the other companies who apply .
In the UK , research by the Financial Times published this month showed that the tax bill of the same seven technology groups in 2012 was 45 million pounds ( 54 million euros) , which considered ridiculous compared to the dimension of business.
Source : Annual reports of companies . / COUNTRY
In Spain , the data analyzed by COUNTRY show much lower payments to the British treasury by those same companies . The net balance is 1.2 million. Microsoft International Holdings Spain faced 10.8 million (of which only 6 are in Spain ), Google Spain, to 1.66 million, Apple Marketing Iberia, to 2.58 million; Amazon Fulfillment Spain 184,000 euros , Facebook Spain 50,000 euros , eBay Spain, 37,000 euros and Yahoo , nothing. But those 15 million (of which four are subsidiaries taxed outside Spain ) were partially offset almost entirely by tax credits or tax to be recovered in the future generated primarily by two companies also belong to these groups : Apple Retail Spain and Amazon Services Spain .
Subsidiaries analyzed by COUNTRY state a turnover of 577.8 million and aggregate losses of 15.8 million . Each has its own story.
Google saves the inspection
The Tax Office launched an investigation in 2011 ended in 2013 with the lifting of records by the corporate income tax for 2007 and 2008 Google Spain . But to pay the additional amount was only 1.9 million without any penalty , which is a big win for the U.S. multinational , since in practice the full legality Hacienda valid model that allows you to not only pay taxes in Spain .
Google Spain Spain still invoiced in a fraction of the income generated . What it does is rebilling costs incurred with a small margin of 8% or 10% to Google Ireland and Google Inc for services marketing and product demonstration and research and development.
Google Spain reported a loss of 1.4 million in 2012 (compared to € 75,000 the red last year) after posting 1.66 million in taxes , especially for supplementary statements of previous years.
Apple stores in losses
Apple, the second company to higher profits in the world, declared losses in Spain . Thanks to the way the group sales invoice , he posted red numbers in a year that broke sales records in the Spanish market, both through its commercial subsidiary sales to third parties and with the company 's own stores .
The maker of the iPhone in Spain operates through two subsidiaries. Apple Marketing Iberia acts as broker for marketing services and sales support from other companies Apple, with sales mainly from Ireland sales to third parties in the Spanish market. The other is Apple Retail Spain , managed the store network group in Spain , the Apple Store.
The bulk of Apple's sales in the Spanish market does not occur through its own network of shops but also through third parties . Apple Marketing Iberia turnover 20.31 million in the year ended September 30, 2012 , according to recently filed with the Companies Registry accounts. Actually , that's only a small commission from sales (this was 1% the last time I posted ) .
Apple, the second with greater benefits in the world, declared losses in Spain
Apple Retail Spain 's subsidiary stores , took a dramatic revenue growth . As sales are retailers , in this case the billing ago in Spain , but the price at which you buy their products (especially two Irish subsidiaries: Apple Sales International and Apple Distribution International) causes the Spanish subsidiary is loss .
Sales of the Apple Store Spanish grew 86 % in 2012 , to 142 million euros. The company started the year with three stores opened and six more during the year. In addition to the costs associated with the opening of six new stores , gross margin (the difference between the price at which the Spanish stores sell their products and what they pay for them to Irish subsidiaries) of the products sold by the Spanish subsidiary is so low that it does not allow you to absorb the costs of rents and staff their stores.
So Apple Retail Spain made a loss before tax of 22 million last year. These losses not only allow you to not pay taxes but also sign in front of Hacienda tax assets ( tax you will save in the future) by 6.5 million , exceeding the minimum taxes paid by the other subsidiary .
Amazon , from Luxembourg
Amazon , the e-commerce giant , has reorganized its activities in Spain after purchasing Buyvip and Spanish opening its online store. The company has transformed Buyvip , her fashion store in a service company , has renamed the Amazon Services Spain and has thinned to take sales to Luxembourg , where also bill the rest of their products. Copy this scheme with his other company , Amazon Fulfillment Spain , which including benefiting from the scheme for SMEs taxed less thanks to the small size which is not billed sales in Spain . The profit before tax is 129,611.7 euros. However, the company declared a net loss because of their expenses are not tax deductible , leading to accounting item of income tax is of 183,941.63 euros.
Meanwhile, the former Buyvip closed 2012 with a turnover of 64.3 million and a loss of 23.6 million , which will generate tax credits of 7,570,000 . Amazon Services Spain accumulates tax losses by about 47 million and deferred tax assets 4 million . This and the change in business model is very difficult to reach the Spanish treasury euro charging a corporate tax of the firm in the near future.
Facebook, only 2 million bill
In Spain Facebook is a tax scheme similar to Google . It is dedicated to the provision of marketing and advertising bill not sold by the social network in Spain . It has a tiny balance , with a capital of 3,006 euros. All their income is the bill to a single client , an Irish subsidiary of the group (Facebook Ireland Services). These revenues were only 2.1 million in 2012 , sufficient to cover a small margin costs , which focus on personnel ( 1.1 million) , rentals ( 175,238 euros) , independent professionals ( 143.383 euros) and advertising and relationships public ( 142,515 euros). The company reported a profit before tax of EUR 155 607 and their full share of the corporate tax was 50,538 euros.
Microsoft , problems with the IRS
Of the seven analyzed tech giants , Microsoft subsidiaries are most taxes paid in Spain . The group founded by Bill Gates has a dominant society header in Spain ( Microsoft International Holdings Spain ) that houses the privileged tenure foreign securities and other commercial operating company and services ( Microsoft Ibérica, subsidiary of the above). Microsoft Ibérica turnover to 120.6 million in 2012 Microsoft Ireland Operations Limited under the contract of commission for the sale of licenses of Microsoft products in Spain . The parent company of the group in Spain declared a profit of 31.3 million and a tax of 10.9 million, although in reality this figure correspond to 4.6 million affiliates that are not part of the tax group , including companies in overseas dependent Spanish .
The group has had trouble with the IRS by the statements of previous years. In November 2011 , the Tax Office minutes lifted following an inspection by Microsoft Ibérica 11.9 million (including interest) for corporation tax in 2004 and 2005 , the company has appealed .
Yahoo , negative equity
Yahoo Iberia is also dedicated to providing services on behalf of other group companies , but its structure is somewhat different. Depends on Yahoo! Netherlands , but bill 86% of sales, primarily in terms of advertising , a Luxembourg company group and 13% to an Irish firm for R & D. The Spanish subsidiary lives with their accounts to the limit, to the point that 2012 closed with a negative equity amounting to 0.9 million , excluding grants 1.4 million. It also has a negative working capital by 22.2 million . The company admits that he had incurred due to dissolution, but was carrying out actions to recover the equity balance . The group has been rescuing the Spanish subsidiary until 2012 through a participating loan that was returned that year. But society had access to a credit line of $ 100 million of the group itself .
eBay, 36,000 euros in taxes
eBay Spain International is billed from overseas commercial activity in the Spanish market. The Spanish subsidiary quadrupled its turnover in 2012 (from 443,109 to 1.8 million euros ) after absorbing Kijiji , but all billing was by way of provision of services to other group companies . This , Ebay Spain ended the year 2012 with a net profit of 97 349 euros, more than double the previous year , after paying 36,000 euros in income tax. In 2011 did not have to pay anything for that concept.
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