アメリカ合衆国の情報技術企業は、アイルランドの子会社などを使い脱税
Gigantes tecnológicos, enanos tributarios
Apple, Microsoft, Google, Facebook, Yahoo, Ebay y Amazon que venden miles de millones en España pagaron solo 25 millones a Hacienda en los tres últimos años
Jesús Sérvulo González Madrid 23 NOV 2012 - 21:27 CET
Tech giants, dwarves tax
Apple, Microsoft, Google, Facebook, Yahoo, Ebay and Amazon selling billions in Spain only 25 million paid to the Treasury in the last three years
Jesús González Madrid Sérvulo 23 NOV 2012 - 21:27 CET
Size Matters . At least when it comes to paying taxes. The Spanish subsidiaries of major multinational technology reduces the most of your tax bill by applying an " aggressive tax planning " , a term that describes Hacienda tax engineering using these groups to avoid paying taxes .
The Spanish branch seven technological giants ( Yahoo , Apple , Google , Facebook, Microsoft , Ebay and Amazon ) paid 25 million tax benefit in the last three years despite Spain generated business worth billions of euros selling their products and services. These companies moved most of the proceeds to other countries with low taxation. These firms use transactions with other foreign affiliates of the group, in countries such as Ireland, Luxembourg and Switzerland , to transfer their benefits to areas with a more advantageous tax or riding facilities and business structures to move profits offshore where almost no will pay to the treasury.
Source : Business Register. / COUNTRY
To tackle this problem , the Ministry of Finance announced on Tuesday the creation of a National Bureau of International Taxation prosecutors to investigate abuses of multinational corporations in Spain . Although many details of the state plan are not known, last week the Secretary of State for Finance , Miguel Ferre , participated in the forum of the Committee on Fiscal Affairs of the OECD in Paris , where he warned of " erosion of tax bases in corporate tax and the transfer of benefits developed for aggressive tax planning strategies countries. " The idea of major international agencies is that companies are taxed in the countries where they generate revenue .
The corporate tax rate in Spain favors the deduction of expenses against other countries that puts the reduced taxation of income . This situation can create a corporate structure that shows the income to other countries with lower taxation and spending to attract more Spanish subsidiaries deductions and credits .
The techniques used by large multinational technology in Spain to reduce taxes on your benefits are:
APPLE
Irish commission
It is one of the most significant cases of this practice to reduce taxes. Apple has several subsidiaries in Spain to exploit the success of their tablets , phones and computers. The group has created a business structure to transfer profits made in Spain to a subsidiary in Ireland , where most bill sales.
The group operates in two ways: through its own stores and sales to third parties , usually large stores and shopping centers.
Apple Retail is the company that manages Cupertino stores in Spain . This company achieved sales of 76.3 million last year when income multiplied by 14 , 2010 , according to accounts filed with the Companies Registry. The company buys the Irish subsidiary with a narrow margin with profit Slimming left in Spain . Despite strong sales increase in 2011, the company only made a profit before tax of 364 138 euros , 0.4% of their income. This is because most of their expenses , 60.5 million coming from purchases Apple Sales International , the Irish branch supplying products with low profit margin to leave Dublin . Ireland has a smaller , 12.5% , compared with 35 % Spanish business taxation . This loophole in international taxation causes only pay Apple 143,115 euros for their tax benefits despite turnover of more than 76 million.
But fiscal engineering goes beyond U.S. multinational . The group uses Apple Marketing Iberia to sell apple products through third parties . This Spanish subsidiary acts as an agent since 1997. That is, it works as " sales support and service provider advertising [ ... ] and receives a commission of 1 % on sales reported for the group ," according to the 2010 accounts . The company suppressed this information from the 2011 accounts when billed 17.7 million , nearly double that in 2009 . If you are still using the same commission supposed to Apple sales to third parties in Spain in 2011 reached 1.775 billion . However , Apple Marketing Iberia only paid tax on business profits of 2.49 million , 0.14% of sales.
Investigated by the Treasury
The Spanish subsidiary of Internet browser manages hundreds of millions of euros in Spain commercials , but last year only 38.3 million turnover . Google Spain is a kind of sales force covering their spending refacturando to Google Ireland and other companies are left with the cake in the Spanish market .
Of the 38.3 million who joined in 2011, 36.9 million did the Irish subsidiary. " The company invoice for services rendered to Google Ireland and Google Inc. on the basis of costs incurred in providing the same plus a profit margin of 8% or 10%." This peculiar tax practice allows hundreds of millions of revenue derived Internet giant arising Ireland . In turn, Google manages to transfer those benefits to tax havens , so that most of the gains escape even the small Irish guy .
Meanwhile, the company in Spain barely covers the expenses incurred . The Spanish subsidiary has reported losses in the last two years. Thus, the statement comes out to return . Finance investigates the Spanish subsidiary of Google . Inspect the liquidation of corporate taxes in 2009 and 2010 . However, these actions do not assume you have been unlawful .
MICROSOFT
Consolidated with the group
The software giant has created a business structure in Spain also allows you to lower the payment of tax on corporate profits . The Spanish subsidiary Microsoft Ibérica acts mainly as a commission of the sales have Microsoft Ireland Operations Ltd. in Spain , as reflected in the annual accounts filed with the Companies Registry. Of the 157.6 million who joined last year, the company billed 80% ( 125 million ) to its Irish sister by commissions from the sales of product licenses in Spain . This means that the Spanish American multinational revenues amounting to hundreds of millions of euros. However , the Iberian subsidiary of Microsoft showed a profit in 2011 of 15 million , of which 6.1 million would pay corporation tax. However, consolidated with the parent company of the tax group in Spain Microsoft International Holdings Spain , which got a tax return of 28 million in 2011. The Spanish subsidiary also has opened an inspection process by Treasury corporate tax for 2004 and 2005 for which the Treasury claims 11.9 million .
Invoice only with Ireland
The Spanish subsidiary of the multinational that runs Mark Zuckerberg declared income 1.7 million euros in Spain , 60% more than the year before last year. Spain 's corporate Facebook "providing advertising and marketing online" object, according to its annual accounts. But all revenue bills to originate from Facebook Ireland Limited, which means that most of the revenue derived from the social networking giant in Spain moved to its Irish subsidiary , while leaving in Spain costs . Last year only 39,740 euros paid corporation tax despite the millions in income of the multinational in Spain , of which the annual report gives little clues.
YAHOO
Businesses in Switzerland
The multinational Internet in Spain also takes the legal and tax loopholes to lawfully reduce your tax bill for the benefits you get in Spain . Yahoo Iberia achieved a turnover of 17.1 million in 2011 , up 9 % over the previous year. The Spanish subsidiary is owned by a Dutch company and make all sales to group companies , mainly Yahoo Sarl ! , Based in Switzerland, it reached a sane by operating as agent acting on its own behalf and on behalf of that Swiss company , which receives a percentage of sales.
This business strategy and implementation of loss carryforwards from previous years has allowed the company to avoid paying corporate tax since it is practically in Spain . The company still accumulated tax losses of the years recorded losses. Meanwhile, receives grants from national and international government agencies.
AMAZON
Operated out until 2011
The activity of Amazon Spain is "To corporate support services primarily to companies in the group ," according to the notes to the annual accounts filed with the Companies Registry. The Spanish subsidiary of Internet commerce began to have income from last year when turnover of EUR 314 417 , a fraction of the millions of euros generated by the shopping portal from Spain . The group sells the Kindle began operating in Spain late last year and the first logistics center opened in May this year. However, most of its operations are conducted through Amazon EU Sarl , based in Luxembourg , another area of low taxation. The group bought the company in 2010 BuyVip . This subsidiary had net sales of EUR 60.9 million last year despite which recorded a loss of 14.3 million .
EBAY
Only works with the group
The Spanish subsidiary of the multinational Internet auction performs all its transactions with group companies , including Paypal Spain and other international subsidiaries to which 443,109 euros turnover in 2011. The multinational moved its sales revenue in Spain to other group firms domiciled in other countries. Ebay International is based in Switzerland. The company has avoided paying corporate tax loss carryforwards to offset other exercises . Between 2009 and 2010 he paid just 9,500 euros.
These tax engineering practices that perform some technology multinationals among group entities to avoid paying the tax authorities are not illegal . However, other large technology companies based in Spain , such as IBM, not practice . The firm established in Madrid in 1941 paid last year more than 30 million, more than the rest of multinational analyzed together in three years.
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