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UndercoverElephant
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Post by UndercoverElephant »

Mr. Fox wrote:
UndercoverElephant wrote:The really silly thing about that article is that it is supposedly science, but that there is no science to be done here.
From the article:
These are not normally scientific questions – but that is changing. Complexity theorists, social scientists and historians are addressing them using new techniques, and the answers are not always what you might expect.
Just to be clear - are you dismissing the study of complexity as a science, or dismissing it's application to the questions raised in the article?
I'm dismissing the idea that it is a lack of imagination which is preventing us finding solutions to the "organisational problems" we're talking about, and I'm dismissing the implied notion that if we could image a better way of organising the way our political system work, that we could impose that better way on the real world. The article is talking about these problems as if they are engineering problems, but there is no engineering solution available.
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UndercoverElephant
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Post by UndercoverElephant »

stevecook172001 wrote:To be fair to UE, what I think he is getting at, and on this I tend to agree, is that whenever we talk about how it we humans decide to organise ourselves, this is as often as not based on underlying philosophical/ethical judgements. Once those underlying judgements have been made, it may then be perfectly possible to apply internally logical or, even, scientific principles in order to implement the organisational consequences of such judgements. However, the initial underlying judgements have got nothing to do with science because they are based on values and, as such, are neither right nor wrong. Or, rather, are both right and wrong, depending on what one's values are.
That's part of it, yes. And the other part is that even if we just assume we can agree on those judgements about what is right and wrong, we can't implement a new organisational model based on those judgements anyway, because the way humans are organised is the emergent result from a complex system that nobody can control.
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UndercoverElephant
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Post by UndercoverElephant »

stevecook172001 wrote:
peaceful_life wrote:.....Jim Sillars interview on BBC'
https://www.youtube.com/watch?v=4WWtRmSJFLs
He pretty much wiped the floor with her.
He makes a lot more sense than either Salmond or Sturgeon.
peaceful_life
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Post by peaceful_life »

Tarrel wrote:
stevecook172001 wrote:
peaceful_life wrote:.....Jim Sillars interview on BBC'
https://www.youtube.com/watch?v=4WWtRmSJFLs
He pretty much wiped the floor with her.
Shame about the "Day of Reckoning" comment though. The "yes" campaign have managed to avoid a lot of that loose cannon stuff up till now.
You mean, he spoke in haste, or did he?...Sillars is no fool.
Last edited by peaceful_life on 14 Sep 2014, 01:04, edited 1 time in total.
peaceful_life
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Post by peaceful_life »

UndercoverElephant wrote:
stevecook172001 wrote:
peaceful_life wrote:.....Jim Sillars interview on BBC'
https://www.youtube.com/watch?v=4WWtRmSJFLs
He pretty much wiped the floor with her.
He makes a lot more sense than either Salmond or Sturgeon.
Because he's not lieing, even though he's way off with the oil mantra, but then, Patrick Harvie, covers that. Watch him, he's not, Alex Salmond.
vtsnowedin
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Post by vtsnowedin »

UndercoverElephant wrote: So there's the answer. The banks move their headquarters to gain the benefit of access to the Bank of England, and their corporation tax would accordingly be paid to the rUK instead of Scotland.

In other words, Alex Salmond was talking utter crap, again.
Could someone please clarify for me. Does a UK business pay its corporation tax all to the location of it's home office or as Salmond has repeatedly asserted is it apportioned to the jurisdictions where the business is actually conducted?
Seems a simple matter of tax law. Only one side can be right on this.
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Post by UndercoverElephant »

http://uk.reuters.com/article/2014/06/0 ... BA20140609
(Reuters) - Nothing about the narrow cream-coloured lobby at 160 Aldersgate Street in the City of London financial district gives a hint of its role at the centre of the offshore oil industry.

That’s because the building is occupied by a law firm. Yet, on paper at least, it is also home to Rowan Companies, one of the largest operators of drilling rigs in the world.

In 2012, Rowan, which has a market value of $4 billion (2.38 billion pounds), shifted its legal and tax base from the United States to Britain. But not much else.

“We changed our corporate structure and we’re legally domiciled in the UK but our headquarters and our management team remain in the U.S.,” Suzanne Spera, Rowan’s Investor Relations Director said in a telephone interview from Houston.

“It has been positive. We take advantage of trying to be competitive with our effective tax rate.”

Indeed, Rowan filings say the shift helped cut the company’s effective tax rate to 3.3 percent in 2013 from 34.6 percent in 2008. Spera said Rowan complies with all UK tax rules.
Right. So if companies based in the US "shift their headquarters" to the UK then instead of paying 34.6% tax to the US treasury, they pay 3.3% to the UK. It follows that if all these banks (there's about 5 of them) relocate from Scotland to London then they will pay corporation tax to the rUK government instead of the Scottish government.

Do not believe a single word that comes out of Alex Salmond's mouth. He's a compulsive, cynical liar.
Little John

Post by Little John »

vtsnowedin wrote:
UndercoverElephant wrote: So there's the answer. The banks move their headquarters to gain the benefit of access to the Bank of England, and their corporation tax would accordingly be paid to the rUK instead of Scotland.

In other words, Alex Salmond was talking utter crap, again.
Could someone please clarify for me. Does a UK business pay its corporation tax all to the location of it's home office or as Salmond has repeatedly asserted is it apportioned to the jurisdictions where the business is actually conducted?
Seems a simple matter of tax law. Only one side can be right on this.
It is apportioned to the jurisdiction where the business is conducted. I can state this unequivocally as I have read, over the last 24 hours, the relevant text from the HMRC site and have also verified this to be the case from several other sites. Please see the relevant section from my previous post on this for details:
....a company with the headquarters in the UK, but with operations in another country will be subject to corporation tax in the following two ways:

If the operation in the other country is classed as a subsidiary company, then the earning from that subsidiary company, irrespective of whether or not they have been taxed in the other country will be completely disregarded in the calculation of UK corporation tax of the parent company.

Or

If the operation in the other country is classed merely as an overseas branch of the parent company, then the earning of the overseas branch, if they have been subject to corporation tax in the other country, are taken into account and are fully offset as a tax relief on the parent company. The specific technical term HMRC uses for this is "double taxation relief "

In either event, Alex Salmond is quite correct in his answer given to Nick Robinson....
Last edited by Little John on 14 Sep 2014, 01:27, edited 1 time in total.
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UndercoverElephant
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Post by UndercoverElephant »

peaceful_life wrote:
UndercoverElephant wrote:
stevecook172001 wrote:He pretty much wiped the floor with her.
He makes a lot more sense than either Salmond or Sturgeon.
Because he's not lieing, even though he's way off with the oil mantra, but then, Patrick Harvie, covers that. Watch him, he's not, Alex Salmond.
I get the impression that Sillars is more aware of the perils of treating people as if they are stupid. Alex Salmond apparently believes that if you smirk a lot and look confident while you spout utter nonsense, it won't matter whether or not what you are saying stands up to scrutiny. I don't agree with everything Sillars says, and not just on oil, but I don't end up feeling like I'm being treated like I'm a fool. My intelligence is not being insulted. And he clearly can't stand Salmond.
Little John

Post by Little John »

UndercoverElephant wrote:http://uk.reuters.com/article/2014/06/0 ... BA20140609
(Reuters) - Nothing about the narrow cream-coloured lobby at 160 Aldersgate Street in the City of London financial district gives a hint of its role at the centre of the offshore oil industry.

That’s because the building is occupied by a law firm. Yet, on paper at least, it is also home to Rowan Companies, one of the largest operators of drilling rigs in the world.

In 2012, Rowan, which has a market value of $4 billion (2.38 billion pounds), shifted its legal and tax base from the United States to Britain. But not much else.

“We changed our corporate structure and we’re legally domiciled in the UK but our headquarters and our management team remain in the U.S.,” Suzanne Spera, Rowan’s Investor Relations Director said in a telephone interview from Houston.

“It has been positive. We take advantage of trying to be competitive with our effective tax rate.”

Indeed, Rowan filings say the shift helped cut the company’s effective tax rate to 3.3 percent in 2013 from 34.6 percent in 2008. Spera said Rowan complies with all UK tax rules.
Right. So if companies based in the US "shift their headquarters" to the UK then instead of paying 34.6% tax to the US treasury, they pay 3.3% to the UK. It follows that if all these banks (there's about 5 of them) relocate from Scotland to London then they will pay corporation tax to the rUK government instead of the Scottish government.

Do not believe a single word that comes out of Alex Salmond's mouth. He's a compulsive, cynical liar.
Scotland will only lose its corporation tax from these companies if the relevant business activities they carry out in Scotland move to the UK. If they only move their headquarters, Scotland will not lose that tax. The business activity that will presumably (since none of these companies has said otherwise) stay in Scotland will generate profits that will be corporation taxed by Scotland. Irrespective of whether the activity is classed as that of a "branch" or "subsidiary company", the government of the parent company does not have access to those taxes and will also not tax the company twice. It's called "double taxation relief" and it forms the basis for international agreements regarding corporation tax. I'm sorry UE, but I have read the relevant text on this and that is how it is. If I've got it wrong, I am happy to be shown where. In which case I will concede the point. But, simply stating he is lying about this (when my own investigations have shown, so far as I can tell, that he is not wrong) in the absence of providing evidence for why you think he is lying, does not make what you say right. As I said, show me where the corporation tax is paid by the parent company to their own government for business conducted in a foreign jurisdiction and I will concede the point.
Last edited by Little John on 14 Sep 2014, 01:44, edited 1 time in total.
vtsnowedin
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Post by vtsnowedin »

UndercoverElephant wrote:http://uk.reuters.com/article/2014/06/0 ... BA20140609
(Reuters) - Nothing about the narrow cream-coloured lobby at 160 Aldersgate Street in the City of London financial district gives a hint of its role at the centre of the offshore oil industry.

That’s because the building is occupied by a law firm. Yet, on paper at least, it is also home to Rowan Companies, one of the largest operators of drilling rigs in the world.

In 2012, Rowan, which has a market value of $4 billion (2.38 billion pounds), shifted its legal and tax base from the United States to Britain. But not much else.

“We changed our corporate structure and we’re legally domiciled in the UK but our headquarters and our management team remain in the U.S.,” Suzanne Spera, Rowan’s Investor Relations Director said in a telephone interview from Houston.

“It has been positive. We take advantage of trying to be competitive with our effective tax rate.”

Indeed, Rowan filings say the shift helped cut the company’s effective tax rate to 3.3 percent in 2013 from 34.6 percent in 2008. Spera said Rowan complies with all UK tax rules.
Right. So if companies based in the US "shift their headquarters" to the UK then instead of paying 34.6% tax to the US treasury, they pay 3.3% to the UK. It follows that if all these banks (there's about 5 of them) relocate from Scotland to London then they will pay corporation tax to the rUK government instead of the Scottish government.

Do not believe a single word that comes out of Alex Salmond's mouth. He's a compulsive, cynical liar.
But UC American corporations are leaving the US because the current tax rates and rules are stupid. These banks threatening to leave Scotland are not planning to go to the US.
So if they leave Scotland and do no business there they will pay no tax to Scotland ' Right? So all that banking business will be sitting there for a new Scottish bank to jump in and treat the Scott customers properly and pay a fair share of taxes to Scotland in Scottish tweeds or what ever they name their new currency.
Little John

Post by Little John »

Precisely.

firstly, they have pointedly not said they are going to cease conducting business in Scotland. Indeed, they have not even indicated that they are going to reduce it from its current level. They have merely said they are going to move their headquarters. which, in many cases, amounts to little more than the relocation of a company plaque. There may be some benefit to them regarding calling on the bank of England as lender of last resort. I am not sure. But, in any event, this has no direct bearing on Scotland save benefiting it by having the bank of England as an indirect lender of last resort despite Scotland no longer being a part of the UK. Hardly a curse wouldn't you say?

All of which begs the question of why these large financial institutions should see fit to make mention of a procedural change which does not affect Scotland deleteriously, and may actually indirectly benefit it? The only plausable answer is they have been leaned on by HMG.
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UndercoverElephant
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Post by UndercoverElephant »

vtsnowedin wrote:
UndercoverElephant wrote:http://uk.reuters.com/article/2014/06/0 ... BA20140609
(Reuters) - Nothing about the narrow cream-coloured lobby at 160 Aldersgate Street in the City of London financial district gives a hint of its role at the centre of the offshore oil industry.

That’s because the building is occupied by a law firm. Yet, on paper at least, it is also home to Rowan Companies, one of the largest operators of drilling rigs in the world.

In 2012, Rowan, which has a market value of $4 billion (2.38 billion pounds), shifted its legal and tax base from the United States to Britain. But not much else.

“We changed our corporate structure and we’re legally domiciled in the UK but our headquarters and our management team remain in the U.S.,” Suzanne Spera, Rowan’s Investor Relations Director said in a telephone interview from Houston.

“It has been positive. We take advantage of trying to be competitive with our effective tax rate.”

Indeed, Rowan filings say the shift helped cut the company’s effective tax rate to 3.3 percent in 2013 from 34.6 percent in 2008. Spera said Rowan complies with all UK tax rules.
Right. So if companies based in the US "shift their headquarters" to the UK then instead of paying 34.6% tax to the US treasury, they pay 3.3% to the UK. It follows that if all these banks (there's about 5 of them) relocate from Scotland to London then they will pay corporation tax to the rUK government instead of the Scottish government.

Do not believe a single word that comes out of Alex Salmond's mouth. He's a compulsive, cynical liar.
But UC American corporations are leaving the US because the current tax rates and rules are stupid. These banks threatening to leave Scotland are not planning to go to the US.
So if they leave Scotland and do no business there they will pay no tax to Scotland ' Right? So all that banking business will be sitting there for a new Scottish bank to jump in and treat the Scott customers properly and pay a fair share of taxes to Scotland in Scottish tweeds or what ever they name their new currency.
Not quite. The reason these banks are moving is not because the rUK will offer a lower tax rate than Scotland, but because if they are in the rUK then they have access to the Bank of England as a lender of last resort, and they have the UK taxpayer to bail them out if they get into trouble. If they stay in Scotland then all they'll have is uncertainty - they won't know what currency Scotland will end up using, or whether or not Scottish banks will have access to a central bank.

But, as a side-effect of them moving to London for the reasons explained above, their corporate tax will be paid to the rUK, not Scotland. They will continue to operate in Scotland - they will make money from Scottish borrowers - but their profits will be taxed in England. This is exactly why Nick Robinson asked the question that Alex Salmond failed to answer.
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Post by UndercoverElephant »

stevecook172001 wrote:Precisely.

firstly, they have pointedly not said they are going to cease conducting business in Scotland. Indeed, they have not even indicated that they are going to reduce it from its current level. They have merely said they are going to move their headquarters. which, in many cases, amounts to little more than the relocation of a company plaque. There may be some benefit to them regarding calling on the bank of England as lender of last resort. I am not sure.
I am. That's the main reason they are moving.
But, in any event, this has no direct bearing on Scotland save benefiting it by having the bank of England as an indirect lender of last resort despite Scotland no longer being a part of the UK. Hardly a curse wouldn't you say?
Scotland will lose the tax on the profits made by those banks. SO....Scottish people will take out mortgages to buy houses from other Scottish people, an English-registered bank will then invent money out of thin air and charge those Scottish people interest on it. And the profits on that activity will be taxed by the rUK government, and any losses during financial crises will be borne by the rUK taxpayer.

Whether that is a blessing or a curse is debatable. Either way, Alex Salmond is a liar.
Little John

Post by Little John »

UndercoverElephant wrote:
stevecook172001 wrote:Precisely.

firstly, they have pointedly not said they are going to cease conducting business in Scotland. Indeed, they have not even indicated that they are going to reduce it from its current level. They have merely said they are going to move their headquarters. which, in many cases, amounts to little more than the relocation of a company plaque. There may be some benefit to them regarding calling on the bank of England as lender of last resort. I am not sure.
I am. That's the main reason they are moving.
But, in any event, this has no direct bearing on Scotland save benefiting it by having the bank of England as an indirect lender of last resort despite Scotland no longer being a part of the UK. Hardly a curse wouldn't you say?
Scotland will lose the tax on the profits made by those banks. SO....Scottish people will take out mortgages to buy houses from other Scottish people, an English-registered bank will then invent money out of thin air and charge those Scottish people interest on it. And the profits on that activity will be taxed by the rUK government, and any losses during financial crises will be borne by the rUK taxpayer.

Whether that is a blessing or a curse is debatable. Either way, Alex Salmond is a liar.
Everything you have written there could be applied to any country anywhere in the word that has, within its jurisdiction, any company whose headquarters are elsewhere in the world. Why is this any more a significant issue for Scotland than it is for everywhere else? This issue is at least as important for England, is it not, given all of the overseas companies operating here?
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