Petek, april 07, 2006 17:19
Pred dobrim letom smo objavili prispevek S skandinavskim modelom v Valhalo, v katerem smo opozorili na nekatere v Sloveniji manj znane skandinavske prakse in na dejstvo, da Slovenija na lestvici ekonomske svobode zaostaja za njimi. Če želimo loviti povprečje skandinavskih držav moramo postati bolj libertarna družba.Hkrati smo v prispevku Matematika proti ideologiji opozorili na dejstvo, da nižje gospodarske rasti na kratki rok ne občutimo, da pa je zaostalost breme, ki ga prelagamo na ramena naših otrok.
Ker je ekonomija naši staršev rasli počasi, moramo mi danes rasti hitreje, da bomo našim otrokom nekoč omogočili zahodni standard, ki si ga zaslužijo.
The Brussels Journal je objavil odlično primerjavo skandinavskega in irskega modela, ki pokaže, kakšne posledice ima spanje na lovorikah na družbeno blagostanje.
Švedska in Danska sta poleg Italije doživeli najvišji padec na lestvici OECD
Irski model je ustvaril neprimerno več delovnih mest od skandinavskih držav
Raziskave kažejo korelacijo med javno porabo in gospodarsko rastjo, višji davki pomenijo nižjo gospodarsko rast
Davčno breme na Irskem je nižje od evropskega povprečja
Javna poraba na Irskem je ena najnižjih na svetu
Naši dragi prijatelji z leve menijo, da je produktivnost posledica motivacije delavcev; ker rast produktivnosti na Irskem presega skandinavske države sklepamo, da so irski delavci bolj motivirani od skandinavskih
vaši prijatelji z leve seveda vedo, na čem temelji irski čudež.
zgodba je čisto preprosta: izogibanje davkom pri evropskih in ameriških korporacijah. ali drugače: davčni dumping. kar pa je težko model razvoja, ker se vsi tega iz logičnih razlogov ne moremo it.
in tako imaš na irskem množico podjetij, ki imajo ducat zaposlenih, prihodke pa milijardne. v USD.
da je temu res tako, pove že primerjava med GDP in GNP. ko upoštevaš to, je irska rast popolnoma POVPREČNA.
drugi faktor je izredno uspešno črpanje evropskih sredstev
tretji faktor je... angleško govoreče prebivalstvo.
slovenija lahko dejansko posnema irsko samo v drugem faktorju.
sploh pa irsko čaka kar nekaj preizkušenj. američani ravno sedaj razpravljajo, kako ameriškihm korporacijam onemogočiti izogibanje davkov na irskem. podobne ideje imajo evropejci.
amerom in evropi je počasi dovolj, da irski razvoj financirajo njihovi davkoplačevalci.
eeeeeeeeeee, kje pa...
Earlier this month, The Wall Street Journal wrote that "a law firm's office on a quiet downtown street [in Dublin, Ireland ] houses an obscure subsidiary of Microsoft Corp. that helps the computer giant shave at least $500 million from its annual tax bill. The four-year-old subsidiary, Round Island One Ltd., has a thin roster of employees but controls more than $16 billion in Microsoft assets. Virtually unknown in Ireland, on paper it has quickly become one of the country's biggest companies, with gross profits of nearly $9 billion in 2004."
Ireland's low corporate tax rate of 12.5% on trading profits has been a magnet for multinational companies who are responsible for 90% of Irish exports and a significant contributor to the success of the modern Irish economy, commonly known as the Celtic Tiger.
In addition, an Irish tax exemption on patent income, has promoted the parking of US multinational company overseas profits in Ireland, through transfer pricing and other accounting measures. Ireland is the most profitable location of US multinationals and in the period 1998-2002, the profits of US companies with Irish facilities doubled.
Ireland's annual corporate tax revenue is about €5.3 billion ($6.3 billion). The Wall Street Journal said in its report that a Microsoft Dublin-based company that is used for routing patent a royalty income from overseas operations, paid the Irish Revenue $300 million in taxes last year.
Ireland is the location of top US tech and pharmaceutical firms. Chipmaker Intel has its largest overseas manufacturing facility in Ireland, computer maker Dell is one of Ireland's largest employers and the top global drugs firm Pfizer, employs around 2,200 people at nine operations in Dublin and Cork. One of the products that it produces in Ireland is Lipitor, the anti-cholesterol treatment which is the world's biggest-selling drug.
The Intel Ireland campus, at Collinstown Industrial Park, Leixlip, County Kildare is Intel's fourth largest manufacturing site overall, and the largest outside the United States.
Intel, Dell, Pfizer and HP are among foreign-owned manufacturing firms in Ireland responsible for 90% of Irish exports.
Wyeth employs around 3,000 people in Ireland, between Wyeth Nutritionals in Limerick, Wyeth Medica in Kildare, Fort Dodge Laboratories in Sligo and the 90-acre Wyeth bio-pharmaceutical campus in Grange Castle, Dublin. This $1.5 billion research and development facility in west Dublin employs around 1,000 people, and is scheduled to hire another 200 over the next two years.
Pfizer Ireland has been a litigant in patent cases across the globe, including one as far away as New Zealand, against its near neighbour in County Cork, Eli Lilly.
On Sunday, The Sunday Independent reported that top executives at Dell Computer's Irish operation - including Vice President of Services and Operations in Ireland, Nicky Hartery - shared nearly $3.8m in tax-free dividends since 2003.
The dividends paid by Dell were paid through a patent royalty company called Dell Research Ltd. Recently filed accounts show that it had accumulated $91.7m in retained profits, none of which is subject to tax under current Irish legislation.
Pfizer alone had $38 billion of unremitted earnings at its international subsidiaries, according to its 2003 accounts.
Up to half of Irish corporate tax receipts may relate to taxes paid on profits transferred from other overseas units of US corporations, to its Irish subsidiaries.
In effect, the Irish tax exemption on patent income, could well fund over 5% of the Irish Government's planned total spending (current and capital) of €48.5 billion, in 2006.
HOW MICROSOFT REDUCES ITS GLOBAL TAXES
The Wall Street Journal said in its report two weeks ago : "Ireland's citizens may not have heard of Round Island One, but they benefit greatly from its presence. Last year the unit handed the government of this small country of four million citizens more than $300 million in taxes.
The citizens of other nations where Microsoft sells its products are less fortunate. Round Island One provides a structure for Microsoft to radically reduce its corporate taxes in much of Europe, and similarly shields billions of dollars from U.S. taxation.
Giant U.S. companies whose products are heavily based on their innovations, such as technology and pharmaceutical firms, increasingly are setting up units in Ireland that route intellectual property and its financial fruits to the low-tax haven -- at the expense of the U.S. Treasury."
The Journal wrote: "Much of Round Island's income is licensing fees from copyrighted software code that originates in the U.S. Some of the rights to these lucrative assets end up in Ireland via complex accounting rules on intellectual property that the Treasury is now seeking to overhaul. The Internal Revenue Service said it is also looking closely at how companies account for such transactions.
In a statement, Microsoft said its European units "report and pay significant amounts of taxes" and that Microsoft "is fully compliant with the tax laws of the United States and all other countries."
Through a key holding, dubbed Flat Island Co., Round Island licenses rights to Microsoft software throughout Europe, the Middle East and Africa. Thus, Microsoft routes the license sales through Ireland and Round Island pays a total of just under $17 million in taxes to about 20 other governments that represent more than 300 million people."
Microsoft's effective global tax rate fell to 26 percent in its last fiscal year from 33 percent the year before. Nearly half of the drop was attributed to "foreign earnings taxed at lower rates," Microsoft said in a Securities and Exchange Commission August filing. Microsoft leaves much of its profit in Ireland, including $4.1 billion in cash, avoiding U.S. corporate income taxes. But it still can count this profit in its earnings.
IRELAND TOP LOCATION OF US MULTINATIONALS' PROFITS
Ireland is the world's most profitable country for US corporations, according to analysis by US tax journal Tax Notes. In a study by the journal's Martin Sullivan that was published in 2004, it was found that profits made by US companies in Ireland doubled between 1999 and 2002 from $13.4 billion to $26.8 billion, while profits in most of the rest of Europe fell. In his analysis Sullivan termed Ireland a 'semi-tax haven' for US firms, because firms are involved in real productivity in contrast with locations such as Bermuda.
Between 1999 to 2002, US multinational corporations increased profits in countries with no taxes or low rates by 68% while sharply reducing profits recorded in countries where they engage in substantial business activity, the study published in the journal Tax Notes shows.
In 2002, US companies reported $149 billion of profits in 18 tax-haven countries, up 68% from $88 billion in 1999, according to Tax Notes, which analyzed the most recently available Commerce Department data. This compares with a 23% increase in total offshore profits earned by US multinationals during the same period-total profits of US multinationals’ foreign subsidiaries around the world stood at $255 billion in 2002.
According to the New York Times, Commerce Department data not referred to in the Tax Notes study, suggest that US companies took 17 cents of each dollar of worldwide profits in tax havens in 2002, up from 10 cents in 1999.
Tax Notes shows that for each dollar of profit taken in Luxembourg in 1999, US corporations took $4.56 of profit in 2002. The result for Bermuda was $2.96; for Ireland $2.01; and for Singapore $1.72. These countries are viewed as tax havens or partial tax havens. For UK, each dollar of profit taken in 1999 was equal to 67 cents in 2002; for Germany, it was 46 cents.
A New York Times report last year notes that, in their public filings, companies are often unclear about what percentage of their profits comes from domestic operations as opposed to foreign operations, and they almost never discuss profit-shifting. For example, Pfizer, the pharmaceutical giant, said in its 2003 annual report that as of the end of last year, it had not made a United States tax provision on what it called $38 billion of unremitted earnings at its international subsidiaries. It was not clear whether that money was actually earned by the international subsidiaries or by Pfizer's operations in the United States and later shifted to those subsidiaries for tax purposes, and a Pfizer spokesman declined to provide any details or comments to the Times.
In October 2004, the Financial Times said that from 1994 to 2003, foreign profits of the six largest US pharmaceuticals companies went from 38 per cent of their overall income to more than 65 per cent. At the same time, the taxes paid on those profits fell from a rate of 31 per cent to 17.5 per cent, just half the US corporate tax rate.
In the case of the drug companies, the growing share of profits booked abroad - most of it in low-tax jurisdictions - does not reflect any significant shift in where those companies do business. Even as their overseas share of profits nearly doubled over the past decade, their overseas sales grew from just 40 to 43 per cent.
IRISH PATENT EXEMPTION
A & L Goodbody, one of Ireland's top law firms, says that patented inventions are a large source of revenue in the pharmaceutical industry. Ireland's tax exemption in respect of certain patent royalties, has been one of the driving factors behind investment by pharmaceutical multinationals, principally from the US, in the Irish economy.
Irish tax legislation provides an exemption from tax for income derived from "qualifying patents" when received by a person resident in Ireland and not resident in any other country. A "qualifying patent" is defined as a patent in relation to which the research, planning, processing, experimenting, testing, devising, designing, developing or similar activity leading to the invention, the subject of the patent, was carried out in Ireland.
A & L Goodbody says that the taxation reliefs to be derived from patented inventions goes further than to exempt the income from patent royalties from tax. Certain distributions by companies made out of income from certain patents which has been disregarded for corporation tax purposes, are themselves disregarded for the purposes of income tax on the part of a shareholder. This has very wide implications for investors in pharmaceutical companies considering carrying out any of their research and development in Ireland.
Maximising Relief for Patent Income
A & L Goodbody says that individuals or companies interested in knowing how to maximise benefits available under the patent royalty exemption should consider the following:
* establishing a separate company to do research and development work for the qualifying patent which will apply for, and hold the relevant patents; and
* this company should so far as is commercially viable, grant licences to unconnected third party users.
Patent royalties received by this company will be exempt from Irish corporation tax, and dividends paid on the ordinary shares of the patent holding company, or on other shares but only to the inventor or co-inventor, will be exempt from Irish income tax in the hands of the shareholders.
Companies are saving hundreds of millions of dollars, and some accounts mention Ireland alongside the Cayman Islands, Isle of Man and British Virgin Islands. Now the US Internal Revenue Service (IRS) and other tax authorities are turning their attention to the issue.
Documents filed at the Companies Registration Office in Dublin show that more household names are joining Microsoft and Google in routing money through Ireland.
Apple Computer Inc Limited, an Irish subsidiary of the iPod maker, had revenue of $2.6 billion in its last filed accounts.
The company owns “manufacturing subsidiaries in Europe and Asia and its sales and distribution subsidiaries in Europe, Australia, Asia, Canada and South America'‘.
It made a pre-tax profit of $214.1 million in the financial year to September 27, 2003, but paid just $8 million in tax. The company paid the equivalent of just 3.7 per cent tax by taking advantage of tax adjustments relating to previous periods. The Apple accounts do not break out revenue per region, because “disclosure of this information would be seriously prejudicial to the interests of the company'‘.
US sources argue that the technology originated in the US and sales should be taxed at its rate of 35 per cent. In a report filed with the US Securities & Exchange Commission (SEC) in August, Apple warned of the impact of “changes in tax laws or their interpretation'‘.
It said it was “subject to the continuous examination of its income tax returns by the Internal Revenue Service and other tax authorities.
“There can be no assurance that the outcomes from these continuous examinations will not have an adverse affect on the company's net income and financial condition.”
Symantec, a US company that makes security software, has also routed significant revenue and profits through an Irish firm, Symantec Limited. It made a pre-tax profit of €253.7 million on turnover of €679.6million in the year to April 2, 2004.
The company has subsidiaries in the Netherlands, China, the United Arab Emirates and Russia, but the breakdown of turnover and profit by region is not provided.
“We receive significant tax benefits from sales to our non-US customers,” Symantec said in a recent filing with the SEC.
“These benefits are contingent upon existing tax regulations in the US and in the countries in which our international operations are located. Future changes in domestic or international tax regulations could adversely affect our ability to continue to realise these tax benefits.’' Accounts filed by an Irish subsidiary of Salesforce.com, a US online software company, also offer an insight into the structures companies use to limit their tax exposure. SFDC International Limited was set up to “hold and license intellectual property rights to other group companies'‘.
In a move to cut its tax bill, however, the company changed its tax residence from the Cayman Islands to the Isle of Man on July 1, 2003, according to its latest accounts.
“Under current legislation, the company is exempt from paying corporation tax in the Isle of Man.”
Online auction company eBay has incorporated a company in Dublin called PayPal International Limited, which handles the online payment services for goods bought and sold on eBay. It has subsidiaries in England, Germany, France, Italy, China and Canada, according to its accounts.
The company had net fee income of €59.75 million in the 18 months from June 2003 to December 2004 and made a loss of €14.6 million, so was not liable for tax. It can use the losses to offset the tax on future profits. Software firm Oracle is making considerable savings using an Irish company called Oracle EMEA Limited. It had turnover of €2 billion in the year to the end of May 2004 and made a pre-tax profit of €553 million. It paid tax of €60.85million, including €9million in “foreign tax'‘.
Other firms have less clear structures. Xilinx Ireland Limited, a unit of a US chip design firm, made a pre-tax profit of $385.2 million in the year to April 3, 2004.
It paid almost $35.6 million in tax, and paid a dividend of $363.1 million to a company called Xilinx Holding Two. The accounts for Xilinx Holding Two describe it as “an investment holding company'‘, which in turn owns 100 per cent of Xilinx Ireland.
Xilinx Holding Two made a profit of almost $320 million in the year to April 3, 2004, and paid no tax. In the previous financial year, it paid no tax on a profit of $67.9 million.
Xilinx Holding Two is owned by Xilinx Holding Six, which is registered in the British Virgin Islands.
Another company, Xilinx Holding One, was wound up earlier this year, while Xilinx Holding Five is non-trading, according to filings at the Companies Registration Office.
Xilinx recently won a case in a US tax court against the IRS, relating to taxes between 1996 and 1999.
Last week, it was reported that the IRS was seeking $476.8 million from a US firm, Synopsys, which has operations in Ireland. The IRS claims that the payment is due because of transfer pricing transactions between the US parent and the Irish subsidiary. Finance minister Brian Cowen last week said the government would not raise the 12.5 per cent corporation tax rate.
Eoin O'Driscoll, president of the American Chamber of Commerce in Ireland, warned that any changes “could negatively impact on our ability to generate and sustain wealth'‘.
" Ireland is another country where GDP has to be read with care. Ireland's position has risen up the GDP per head rankings since 1999, and is now in the top five countries in the OECD. ...But does GDP per head accurately reflects Ireland’s actual wealth, since all that inward investment (and foreign labour) generates profits and other revenues, some of which inevitably flows back to the countries of origin?
Another measure, Gross National Income, accounts for these flows in and out of the country. For many countries, the flows tend to balance out, leaving little difference between GDP and GNI. But not so for Ireland, as outflows of profits and income, largely from global business giants located there, often exceed income flows back into the country. This means that in a GNI ranking, rather than being in the top five, Ireland drops to 17th. In other words, while Ireland produces a lot of income per inhabitant, GNI shows that less of it stays in the country than GDP might suggest. "
drugim v poduk. pri tebi pa itak ni upanja.
In največ je najbolj perspektivnih podjetij(IT,farmacija...).
In tudi če se podjetje skuša izogniti davkom, na količini Irski še zmeraj prinese toliko davka, da si manejo roke.
In mislim da na Irskem ne živijo slabo...
Irska je liberalizirala trg, uspešno znižala davke in zaradi nižjih davkov, se na Irskem le-tem manj izogibajo in jih plačajo več.
Irska je podjetništvu prijazna država.
an exercise in futility
"Irska se ne gre nobenega davčnega dumpinga"
seveda ne. eh, kje pa... WSJ se je sam hecal.
pa kje delajo tako dobro lobotomijo?
In beseda davčni dumping za Irce nima pomena, je samo izgovor za vse ostale, da ne naredijo česa podobnega...
O vernikih ki jim je država oltar pa kdaj drugič...
http://en.wikipedia.org/wiki/Celtic_Tiger
2. Pravzaprav sploh ni pomembno, kaj se gre Irska, pomembno je, da to zelo dobro deluje. Nizki davki, majhna poraba in največje blagostanje v EU - to je pač odličen rezultat.
2. irski primer ni noben dokaz lafferja. prosim, da si lafferja ponovno prebereš in razmisliš, zakaj ne (namig - laffer ni imel v mislih ustvarjanja tax haven-ov)
3. uspešnost irskega modela v bistveni meri temelji na tem, da so druge države sistematično seljenje prihodkov na irsko tolerirale. dvomljivo je, da bi tako delovale tudi pri drugih državah (še posebej, če bi jih bilo več) in danes - s tem pač njihovi davkoplačevalci plačujejo za irski razvoj. da se tudi potrpljenje glede irske počasi končuje, kaže članek v WSJ
4. irski razvoj je neločljivo povezan z nepredstavljivimi milijardami evrov denarja iz skladov EU (zelo neoliberalno, a ne???) - toliko denarja za druge ni več na voljo, še najmanj za nove članice (spet denar evropskih davkoplačevalcev, huh)
5. primerjava med GDP in GNP ter GNI kaže, da so a) dejanski prihodki, ki so na voljo ircem, precej nižji b) da je irska gospodarska rast, gledano po GNI, v zadnjem obdobju povsem POVPREČNA - na ravni kontinentalne evrope
6. kako je irski uspelo je pomembno, če iščemo recepte. in irski uspeh je bolj malo povezan z neoliberalnimi recepti
7. neoliberalnih analitikov sploh ne zanima zgodovina - dejstvo, da je recimo skandinavske države v 90. letih izredno prizadel propad sovjetske zveze (zlasti recimo finsko, pa tudi švedsko), da nemčija še vedno plačuje združitev... irska takih šokov ni beležila.
strokovno sem se izpopolnjeval na irskem, kjer smo obravnavali tudi t.i. irski čudež. irska kot model za nove članice EU? tako nekako se je glasil naslov konference na kateri sem sodeloval in kjer sem se imel priložnost pogovarjati z eminentnimi irskimi ekonomisti. skrivnost niso evropski skladi: v 60% irsko gospodarsko rast po vstopu v unijo pojasni staromodni model izkoriščanja delavcev - ti namreč na boomu niso participirali v tolikšni meri, kot bi lahko. kontrola plač je podjetjem omogočila razvoj - podobno se dogaja danes v nemčiji, kjer rast izvoza temelji na znižanju realnih plač nemškega delavstva.
Vprašanje zakaj je bilo treba v Nemčiji sedaj znižati plače?
Spet se mi poraja občutek, da zaradi prevelikih socialnih transferjev iz preteklosti.
Ali se motim?
zanimivo je tudi, kako se razlikujejo kazalci poslovnega in potrošniškega zaupanja v nekaterih članicah EU: medtem ko menedžerji polni upanja gledajo v prihodnost, saj se mastijo z na pleči delavcev pridobljenimi profiti, so garači zaradi manjših plač bolj resignirani. prerazdeljevalna logika turbokapitalizma, ni kaj.