king_pellinor | Recent Entries

A couple of weeks ago we finally got to start playing a 5th Edition D&D campaign, that was meant to happen last year but, you know...

Anyway, I spent those 2 years building a character sheet in Excel, and one of the functions that gradually accreted (along with an automated inventory-tracking system, drop-down boxes for prepared spells, and a dynamic system for keeping track of which initiative die to roll) was a journal. The one I kept was a bit rough and ready, but (polished up only slightly) here it is:
*********

The Journal of Kit Kill's Adventures in Sigsland

After leaving Home, I joined a Caravan that was heading East into Sigsland, which is a dangerous place that means caravans need Guards. Luckily for them I am a good fighter with my own Arms, Armour, and Horse, so they were quite glad to have me along and promised me Twenty Shillings when we reached Phandalin, which is where the Militia from Irilian would take over.

People in the caravan include:

Osric the Caravan Master

Sister Undrilla, a Cleric of the Church

The Chief Guard, whose name I can never remember

Gerda and her daughter Justina, Travellers

Rudolf Schuhmacher, a Gnomish Travelling Cobbler and Wizard

Leafwish Barksong, an Elven Bard who doesn’t like the Church very much at all

Sister Zvesda, an Elven Cleric not of the Church

Martin Bowmanen, an Archer who doesn’t say much but is Guarding the caravan

Vreth and Vyth, Lizardfolk who I think are Sister and Brother (in that order) who are also Guarding the caravan

( Read more... )

I am not one to wax lyrical about things, but I've just been given a copy of Emma Newman's Planetfall for Christmas, and having just read right through it in one sitting I feel moved to break the habit of a lifetime and actually say something about it rather than just going on to the next book. Not to mention posting on LJ again after several years.

( Read more... )

Quick question for those who know this sort of thing: what's a decent new graphics card to get?

LadyofAstolat wants to play the new Deus Ex, which says it needs at least a GeForce GTX660, or ideally a GTX970 (or equivalent).

Whereabouts are we on the tech curve with those? Would a 970 be a good buy these days, or is the sweet spot somewhere up or down from there?

I've just come back from a very nice weekend away in Dorset, in where the excellence of the walks was enhanced not only by the addition of tea shops and pubs every mile, but also by a decent leavening of second-hand book shops :-)

I suspect that LadyofAstolat and I may not have been taken seriously as Walkers, what with our sandals instead of boots and small carrier-bag-full of books instead of a proper rucksack, but hey ho.

Anyway, I am now the proud possessor of a book called Our Wonderful Armed Forces, which seems to have been published in around March 1940. I've barely started it so far, but I did flick trhough it in the shops. A few spoilers:

- People were worrried before the War that there might be aerial bombardments of cities. It has however become clear that if Hitler were to try it his losses would be extremely heavy, so that's never going to happen.

- The Me109 is OK as a plane, but not nearly as good as a Hurricane, and in fact German pilots don't like taking it into combat. The Me110 is better, but still not as good as a Spitfire

- The Spitfire is about the be supplemented by a plane with a turret-full of guns behind the pilot. This will make the Defiant an amazingly good fighter.

- The Army has super-heavy tanks weighing alsmost *16 tons*, whose 2-pounder guns pack a tremendous punch.

- Germany did very well in Poland, and there are lessons to be learnt from that campaign, but the Germans are clearly never going to manage anything similarly dramatic in the West.

As the young lady in the shop said, it's a snapshot of history :-)

The cut-out bit of door from when I put the catflap in over 10 years ago, that I have been carefully keeping in case it ever came in handy, has come in handy!

I gloat! Hear me gloat!

Thanks to keeping something that had no apparent earthly use, I can confirm that the hole is neither too large nor too small for the new catflap.

Ti ra ra la i tu! I gloat! Hear me gloat! :-) :-) :-)

If anyone wants this and hasn't got it, it's apparently free on Steam until late tomorrow. All you need to do is go and download it.

Apparently the South Croft tin mine in Cornwall is going into administration. From the article I read which announced this:

"There have been several challenges to operations at South Crofty which have made it difficult to attract investment. These include UNESCO’s objections to mining operations taking place in the area designated as the Cornwall and West Devon Mining Landscape, which is protected as a World Heritage Site."

Well done UNESCO, I quite agree. Mining is entirely out of place in a mining area. It would be like taking a school, a place of quiet learning and development for young people, and filling it with children and all their noise and disruption.

I wear a suit for work these days. When I get home I usually go upstairs to the armoury to change out of it, to avoid getting dinner all over my good shirts and better trousers.

Question: having removed suit, shirt and tie, which is the more sensible approach to putting on a t-shirt and casual trousers?

A) Trousers first, so although you can't see where you're going as you walk downstairs while pulling a t-shirt over your head you at least have unencumbered feet.

Or

B) T-shirt first, so although you have no control over your legs as you walk downstairs while putting your trousers on you can at least see where you're going.

Despite repeated empirical testing I can't honestly say which is better, so I thought it might be useful to try getting some theorising to determine the question. Any thoughts?

( This is far too long for anyone not there to read. And possibly for those who were... )

I've started a new blog about tax - partly to be about the avoidance thereof, and partly to be about bits I think are unfair the other way. It occurs to me that I probably ought to tell people about it, though :-)

I've done it entirely separately from LJ - mostly as I think it's going to end up TLDR - but if anyone's interested it's over here: http://andrewjjackson.wordpress.com/

I may still rant here, of course :-)

Mike Truman, editor of taxation magazine and a very well respected figure in tax circles, is a bit upset by the Public Accounts Committee.

He's done an opinion piece in Taxation, which I think is open to view without a sbscription: http://www.taxation.co.uk/taxation/Articles/2013/02/06/53361/tax-prat-year

I'd urge everyone to read it, as the PAC's approach seems to mirror what the papers are saying so Truman's comments apply quite widely across the current tax avoidance debate.

I listened to yesterday’s Public Accounts Committee meeting with the Big 4 accountants yesterday.

It was billed as a chance for the PAC to collect evidence about tax avoidance. In fact it was just a soapbox for Margaret Hodge to browbeat a load of straw men. She made herself look absolutely ridiculous, in my eyes: she seems to think she’s a headmistress telling off some naughty schoolchildren. Austin Mitchell wasn’t much better, though he was fairly inarticulate most of the time so it was hard to tell.

Hodge clearly has an idea of what happens in business, and although she was supposed to be collecting evidence she set out far more “facts” than the witnesses did. Her refrain was “I don’t agree”, whenever someone made a valid point that ran counter to her prejudice. I cannot see that she will have changed her mind in any way, but then I don’t think she intended to: all she was after was to try to get the Big 4 people to admit something she could attack them for.

( Running through my notes... )

This is from the speech made by John Andrews, founder of the Low Incomes Tax Reform Group, on being given an award recognising his efforts to help peope who have trouble with their taxes. Note that he deals with the complete opposite end of the spectrum from multinational companies.

...a report in the US press last year [credit here to Rex Huppke of the Chicago Tribune] made Facts into a mythical person and then criticised US politicians for killing Facts. The event that caused the demise was when a Florida Republican announced, without any evidence, that at least 81 of his fellow members of the U.S. House of Representatives were communists.

This made me think that some tax debates may have pushed our equivalent of the mythical person, Facts, to an early grave here in the UK.

Facts had a long life and I believe was born in ancient Greece, the child of Aristotle who saw that evidence was essential for his nurture. As Facts grew up people like Edmund Burke observed "Facts are to the mind what food is to the body."

Facts helped to discover gravity, break the Enigma Code, discover DNA and, perhaps, introduce self-assessment.

In 2012 however, people seemingly unable to understand how tax systems work, began to doubt and ignore Facts. Opinion became the new truth and reprinting of such opinion in the press confirmed this new truth as correct. No feedback from Facts was thought necessary.

Facts had suffered serious injuries at the time of the 10% tax rate debacle in 2008 and through the misplaced assertions in 2010 about millions of errors being produced by the new PAYE system.

His health was improving, when early last year he was laid low by the absence of any sensible discussion about the granny and pasty taxes.

But nothing was to prepare him for the cruel assault which led to his demise in the final month of twenty-twelve. Assertions in the press that you can judge the right amount of tax a multinational should pay by looking at its turnover; followed by the revelation that for certain there was a £69.9 billion tax gap caused by avoidance, caused Facts to have a major stroke.

He was still in intensive care in hospital when the final straw came. His cousin TaxLaw was the one to break the news. TaxLaw had been admitted to the hospital’s isolation unit and had been ignored by all and sundry, including, at times, the Public Accounts Committee. The oxygen was rushed to Facts when he was told that a coffee bean company was now to be the arbiter of the amount of tax that people should pay; but it was too late.

That news coupled with the whisper that a burger chain would set the CPI in future had done its worst.

You will have seen from his obituary that Facts was aged 2,372 and was buried, at his request, in the birthplace of Parliament - the Isle of Man. He is survived by two brothers Rumour and Dogma and a sister Shout Loudly.

Donations in his memory may be made to HMRC in a brown envelope marked “corporation tax”.

I hope that the CIOT pro-actively pick up the challenge in 2013 to ensure the resurrection of Facts and to protect his cousin Taxlaw from also being sent to an early grave.

Richard Murphy, the Tim Coates of the tax world, has recently banned me from posting on his blog.

Apparently, when I suggest that a company should follow the laws of its home country, rather than those of a country it doesn't operate in at all, I am promoting crime.

Presumably crime is now defined as "doing something Murphy disapproves of ", rather than that outmoded "breaking the law" thing.

Oh Woe.

Current Mood: Distraught

Campaigner criticises MPs over avoidance debate

"Other parts [of the debate] contained a distinct lack of facts, accompanied by impossible dreams, misunderstandings and many unsupported assertions."

Quite right too. I've skimmed the transcript of that debate, and it's rubbish. The aim is laudable, but there's no understanding of the real situation, the problems which arise, the solutions which are being applied now, or the possible solutions which could be applied.

Oh, lord, they're at it again. This really is scraping the barrel.

"Tui Travel admits it did not pay any corporation tax": http://www.bbc.co.uk/news/business-20590961

What devilry is this? No tax paid, on profits of £390m? Surely some immoral manipulation of arcane accounting rules!

Er, no. They lost a lot of money one year due to the ash cloud, then spent another load on restructuring and are only just starting to recoup the money they spent on it. Net position: they've made no money for a few years, so there's nothing to tax. For Pete's sake, this is a complete non-story.

And where did that "admits" in the headline come from, anyway? Surely the reporter found out because it was in freely-available public information, and the company saw nothing wrong in being in a perfectly ordinary position! I seriously doubt it took any pressure.

What's next?

OK, OK, I admit it, I paid no corporation tax last year, in fact in my working career I have never paid any! Like TUI, I use a really complex accounting dodge called "not making any profits chargeable to corporation tax", although in my case I take it a step further than that and ensure that I never will make any by carefully structuring myself to, in the technical jargon, "not be a company". I maintain that I have done nothing wrong, and have complied with all relevant tax laws.

Call me immoral if you like - I am unrepentant and care not for boycott.

Richard Murphy is a name that crops up time and again in news items about tax, along with the Tax Justice Network and Tax Research UK, campaigning groups he's involved in which seem to punch well above their weight in terms of media exposure.

To me, quoting Murphy in support of your position is shorthand for saying "I want to jump on the bandwagon, and here's someone who's always ready to provide an apparent Authority which absolves me from doing any actual research" - there's no point reading the article, because if Murphy is quoted then the useful fact content will be nil. I've never found him say anything I agree with yet.

I can't tell whether he's keen but out of his depth, or whether he knows that what he's saying is bollocks but it serves his purpose. I suspect that actually he doesn't care whether what he says is true or not.

For example, on his blog today he quotes something saying that someone or other has as much wealth as the bottom 48 million Americans combined. Someone commented that as the bottom 25% of American households are apparently in debt, and 25% of the population is more than 48 million, the net wealth of these 48 million is presumably nil; so on that basis her 4-year-old daughter is also richer than 48 million Americans combined and so it's not a useful thing to say. Murphy responds that this is pedantry, you can always argue about stats, and it's the message that's important. And so, I assume, the facts aren't: if you're sure the conclusion is correct, you can make up any evidence you like to support it. I don't like that sort of approach.

But this is typical of the way the media at the moment is taking big numbers and waving them about as if they're important. I've already ranted about comparing tax paid to turnover, simply because turnover is a bigger number so it looks more impressive. Can't they use sensible figures but just put them in a bigger font? At least that's just fiddling with presentation, not distorting the position.

He's also gotten a load of basic tax calculations wrong - he corrected someone else's article a month or two ago, but got his corrections wrong because he was proceeding along completely the wrong lines. He then spent quite a while arguing that it didn't matter because you'd end up with the same result anyway, but, er, no you wouldn't. But I note that he doesn't take correction: he's right, or the conversation stops.

So in short, I think he knows just enough about tax, accountancy and economics to be dangerous: he thinks he's an expert and infallible, when he's actually fairly incompetent. However: he has an agenda he wants to push, he knows enough to dress it up in plausible-sounding language, and he's happy to give a soundbite to any reporter keen to push the same message. At the moment his views are fashionable, so he's getting a lot more exposure than the real experts who try to explain that it's more complicated than they think and perhaps the companies aren't necessarily being Evil.

Even shorter: don't believe a word he says. If he said the sky was blue I'd look out of the window.

There seem to be two main issues that the PAC is complaining about.

The Starbucks issue is that it's a big business but isn't very profitable even though it tells people things are going well. So what the PAC wants to do is scrutinise the amounts Starbucks pays to related parties to make sure they're not inflated to avoid UK tax.

So we need to set up an official arm of the UK Government with powers to examine the accounts and tax returns of large companies to make sure they don't do uncommercial things. Oh, wait, that's exactly what HMRC is meant to do, and in fact has done - as evidenced by the reducting in royalties from 6% to 4.7%. So, er, nothing for the PAC to look at here.

The Amazon/Google issue is different: the issue for them is that they're located outside the UK and selling into it, which is made a lot easier by the web. So when someone in the UK buys from them, the profit on that sale is taxed outside the UK. So what the PAC wants to do is make sure that it's taxed in the UK.

Only... if you apply that across the board, then every company selling across the web will need to carefully keep track of where its customers are, and file tax returns in every single country they come from. Bit of a bugger for businesses, especially small ones - you either have an impossible administrative job, or you have to refuse sales, or probably both. This was considered in the VAT context a few years ago, and the EU decided that the only way to make things work was to have the VAT chargeable where the supplier is, as otherwise there'd be no sales to charge VAT on.

Also, for every person on the outside selling in, you have people on the inside selling out. So doing this would strip a lot of profits out of the UK tax net. Ignoring balance of payments issues, it would have no effect on tax revenues - except for the fact it now makes it much harder to sell anything, so the economy goes downhill and taxes fall.

The other thing might be to look at the definition of "Permanent establishment". At the moment marketing and distribution are regarded as ancillary to the main business of selling, so if you have an overseas company with a warehouse in the UK then it doens't necessarily have a taxable presence here. There may be some scope in looking harder at that area to see if maybe some marketing/distribution operations are substantial enough to count as establishments. At that point, the UK gets a cut. Again, this is something you need to look at both ways round, and would be a major international discussion point, not something you can do unilaterally.

So what the PAC wants to do is stop meddling in what it doesn't understand. Oh, and maybe think about funding HMRC properly so they can get on with doing the job that they're actually surprisingly good at (for all I say about them).

The PAC has published a report based on the discussions it had with Starbucks, Google, and Amazon here: http://www.publications.parliament.uk/pa/cm201213/cmselect/cmpubacc/716/71605.htm

It talks about the tax paid by a company in the context of its turnover. It accuses HMRC of failing to show that avoidance is not increasing, as if that is evidence that it is. It complains that HMRC, a department whose staffing has been massively cut, might not be acting robustly enough. It several times says "we weren't convinced of X", but never sees fit to provide any evidence for concluding not-X. It seems to think that agreeing how to tax something in the Netherlands is an arrangement designed to remove things from UK tax, rather than an exercise of that government's sovereign rights.

Above all, it harps on about looking at where economic activity takes place, but seems entirely ignorant of the normal rule that to decide this you look at where the contract is made. It betrays no understanding of the Permanent Establishment clauses of tax treaties, which are in there precisely to resolve this sort of issue, which have been carefully negotiated by the UK Government, and which almost universally agree that marketing and distribution operations do not constitute a taxable presence in a country.

But it comes to no conclusions whatsoever, beyond a general feeling that the companies and HMRC are in the wrong, somehow. Or rather, the cynic in me says, that the MPs want to show that they are in the right and therefore need to find someone else to be in the wrong.

Current Mood: annoyed

Starbucks is being slated for paying royalties from the UK to reduce taxable profits. Apparently no-one pays royalties for any other reason.

Couple of things here: first, er, yes they do. It's what the whole franchising business is based on, for one thing. I don't think there's a Starbucks on the Island, but I'm pretty sure that if I set up Starbucks IW Ltd and opened a coffee shop called Starbucks, the existing Starbucks group would want a cut of the action. It's not a tax trick, it's not even an accounting thing, it's a perfectly ordinary business arrangement.

Second, if we start saying royalties shouldn't be taken into account for tax purposes, what happens to all the royalties received by UK companies? ARM, for example? Or indeed any company working in the new Intellectual Property sector that people are saying is the future for UK business? Do they get all their income tax-free?

Or is it just that royalties are a bad thing when they go in one direction? No-one's mentioning that they're taxed where received. OK, they're not taxed very much in the Netherlands, but that's for the UK to complain about to the government of the Netherlands. It's the sort of thing wars have been fought over, if I remember my history properly.

Third, Starbucks apparently has a global agreement to pay royalties at 6% of turnover, which is in the sort of ballpark I'd expect. HMRC argued it down to 4.7% for UK tax purposes, probably because HMRC will always assume that anything you're paying will be too high (which can be a reason why you go for the highest reasonable number). So it's both a standard thing across the board, and HMRC have agreed that it's being deducted at the right level. So Starbucks UK is acting like a perfectly commercial company whose tax affairs have been approved by the authorities. The swine!

It all comes down to profit, and the fact that they don't make any.  Royalties only come into it because people look at the profit/loss line, and then say:
     - If you didn't have this number here that I don't understand you'd make a profit.
     - Therefore the only reason you don't make profits is because of this number here.
     - Therefore the only reason to have this number is to avoid profits.

Of course there are any number of things that would have a bigger effect on Starbucks's profitability than the royalties: turnover and wages, for two. I've seen it suggested that if everyone went out and bought an extra cup of Starbucks coffee, we could pretty much force them to pay UK tax as that income would go straight to the bottom line. Equally, if they'd just cut wages they'd get the same effect.

So when it comes down to it, Starbucks avoid tax by a) not selling coffee and b) paying their staff. Immoral swine!

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Notes from a very small island

Recent Entries

Kit Hill's Adventures in Sigsland

Planetfall

AKICOLJ - PC upgrades

Our Wonderful Armed Forces

Ti ra ra la i tu! I gloat!

Left 4 Dead 2 is free for Christmas

Quite right too

Question that has been at the back of my mind for a while

An RPG of Thrones part 5 - A Misuse of Maesters

New blog

Tax Prat of the Year

Tax ranting # 11 - In the Headmistress's office

The tax avoidance "debate": an elegant summing up

Tax ranting #10 - Free speech

Tax ranting #9 - Hear Hear

Tax ranting #8 - losses

Tax ranting #7 - Richard Murphy

What the PAC wants to do