Starbucks, Amazon & Google

While this entry does not comprise one, or even a group, of individuals, it does represent perhaps the biggest influence in international corporate tax in the past year.

The corporate tax affairs of these three US-based companies were initially placed under the spotlight by the UK government, which initiated a global and public debate about how large multinational companies organise their tax affairs - in particular those relating to their intangible assets - in terms of the profit they book in certain jurisdictions.

This strengthened support for the OECD project on base erosion and profit shifting (BEPS).

It is these three companies that have become synonymous with the public debate on tax avoidance over the past year, though Amazon and Google have been highlighted a number of times before for suspect tax arrangements, where certain jurisdictions do not feel they are getting their fair share of the companies’ profits, and the debate usually centres on the companies’ use of intangible assets.

The BEPS project and the OECD’s project on the transfer pricing aspects of intangibles will hopefully make the treatment of intangible assets easier for taxpayers and authorities to negotiate.

A recent development includes the EU’s move to amend corporate tax legislation across the bloc and introduce an anti-abuse clause, aimed to stop the kinds of structures used by companies such as Starbucks, Amazon and Google, which are seen as aggressive by shifting money away from countries where they book high profits.

The Global Tax 50 2013
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