欧洲不再是避税天堂？

外国跨国公司的避税问题一直为人所诟病，但谷歌事件至少表明即使是财大气粗的谷歌，也无法避免政治风向的转变。

测试中可能遇到的词汇和知识：

paltry 微不足道的['pɔːltrɪ; 'pɒl-]

permanent establishment 常设机构

parliamentary 议会的[,pɑːlə'ment(ə)rɪ]

assertion 声明[ə'sɜːʃ(ə)n]

multinational 跨国公司[mʌltɪ'næʃ(ə)n(ə)l]

barrister 大律师['bærɪstə]

duck 闪避，鸭子[dʌk]

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The UK tax authority must apply some muscle towards Google （432words）

By Delphine Strauss

* * *

Google’s deal to settle its UK tax affairs with a paltry £130m payment leaves plenty of unanswered questions. The central issue, though, is whether Google should be forced to concede that it has a taxable presence, or “permanent establishment”, in Britain, making it liable to corporation tax on profits from its UK sales.

Until now, Google has avoided paying UK corporation tax because it argues that sales of advertising space to UK clients take place in Ireland. It classes its UK operation as a branch office, books the sales in Ireland and channels the profits to Bermuda.

HM Revenue & Customs appears to be leaving this structure essentially intact, although the OECD has recommended changes to the definition of “permanent establishment”, so that it would apply to operations that play “a principal role” in the negotiation of contracts, rather than simply to those that conclude contracts.

The OECD proposals, approved by G20 leaders in November, do not yet have legal force and the US, in particular, will not apply them. They are however an indication of the way policy is evolving at international level.

As far back as 2013, Google’s assertion that none of its UK-based staff was engaged in sales earned it the derision of a parliamentary committee, which pointed to the sales targets and sales-related bonuses of employees dealing with the company’s biggest UK clients. About 700 UK employees were working at the time in marketing and digital consultancy: many were recruited for their sales skills and were able to negotiate prices and agree sales, even when the final billing took place in Ireland.

The committee said HMRC had not done enough to challenge the “manifestly artificial” tax arrangements of multinationals, noting that it had never tested an internet-based company on permanent establishment in the courts.

Jolyon Maugham, a tax barrister, says there are “a lot of data points that would lead you to the conclusion that Google does operate a permanent establishment in the UK”.

Other countries, including France and Italy, have taken a much tougher approach to similar tax avoidance structures, with Paris reportedly seeking up to €1bn from Google even though its French business is much smaller than its London operation.

HMRC appears to be ducking the fight. But if it gives up on Google, it will struggle to reach a better settlement with other fast-growing companies — Uber or Airbnb, for example — that are attracting the attention of tax authorities elsewhere.

If ministers hoped to defuse public anger over the apparent ease with which big multinationals can minimise their tax bills, they will have to think again.

请根据您所读到的文章内容，完成以下自测题目：

1. Where did the Google’s sales of advertising space to UK clients take place?

a. Irak

b. Bermuda

c. Ireland

d. London

2. Who approved the OECD to solve the tax problem in November?

a. HMRC

b. American Government

c. G20 leaders

d. WTO

3. How many UK-based staff were engaged in sales as Google said in 2013?

a. 700

b. 0

c. 130

d. 20

3. Which one will possibly be the next target about tax arrangements?

a. Baidu

b. Google

c. Youku

d. Uber

[1] 答案c. Ireland

解释：即使身处英国的客户，若想向谷歌投放广告，也得与爱尔兰的公司联络。

[2] 答案c. G20 leaders

解释：11月经合组织建议，组织跨国大型企业理由复杂但是合法的漏洞达到避税的目的。

[3] 答案b. 0

解释: 早在2013年,谷歌的断言没有英国员工从事销售,但是实际上并非如此。

[4] 答案d. Uber

解释：这些发展迅速的大型跨国企业总是更容易吸引各地税收机构的关注。