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Milestone is an independent practice of lawyers Where it does not consider them appropriate or fit for specializing in international tax law. In the interests of purpose Parliament alone has the power to amend these disclosure, we do not and have never advised Amazon. We do, however, take a keen interest in the issues facing this particular multinational business and those We hope you find this first Milestone Tutorial of interest companies currently targeted by MPs, the press, left- and look forward to hearing any feedback you might wing bloggers and disgruntled competitors.
We agree that the time is nigh for the Government and The (European) Amazon Tax Structure
HMRC to consider a radical overhaul of the UK tax Our educated guess at the Amazon corporate structure system. It is ludicrously complex, long and in places for its European operations is as follows: very badly drafted. However, the populist view that all multinationals are evil, immoral and unjust is not the basis on which a review of the UK tax system should be undertaken. The Public Accounts Committee showed, - Amazon’s European business is Headquartered in with alarming alacrity, the ignorance of those running the UK and responsible for setting the future direction of tax - The servers on which the Amazon website is hosted - Amazon.co.uk is a trading name of Amazon EU Sarl, Any debate, tax or otherwise, must be conducted impartially with those involved being well-informed. - Amazon EU Sarl sells products either as principal or Unfortunately, perhaps because tax is so complex, but more likely because it is so emotive (especially during - When a consumer buys a product via Amazon.co.uk times of austerity), much of the current debate has they are buying from Amazon EU Sarl (i.e. a non-UK simply ignored established tax principles and instead relied on “soap-boxing” and name-calling.
- Amazon EU Sarl has a UK incorporated subsidiary With this in mind, we thought it would be useful to that operates several warehouse, picking, packing provide you with a brief tutorial of the tax principles applicable to the Amazon business. Due to the lack of - Other such facilities exist in France and Germany; publicly available information on Amazon’s corporate - Some goods sold by Amazon EU Sarl will be held in structure, we have had to make certain assumptions UK warehouses and distributed from there, others about the Amazon business model, but are confident will be distributed by the EU warehouses; that the structure outlined below is established and - Legal title to the inventory held by the warehouse governed by the tax principles and laws we have The General Principles of Tax Law Applicable
We have attempted to make this Milestone Tutorial as to E-Commerce
clear and concise as possible, making it accessible to all our readers including newcomers that have, perhaps, Amazon is a fundamentally different business to, say, never heard of a double tax agreement. Our aim is to HMV or John Lewis. First and foremost it is a foreign (i.e. re-start the current debate and to stress that despite non-UK) headquartered and owned business. Secondly, the use of inflammatory words such as “tax dodger”, it is an on-line retailer. Its business is conducted over “unjust” and “immoral” companies like Amazon have the internet; customers buy goods via a website / server done nothing illegal. The tax principles that multinational that is located in a foreign jurisdiction. This is critical to companies rely upon are based on established economic the tax analysis and to understanding any argument put theory – principles that have been entrenched in our tax forward to change the way in which companies such as system for at least 50 years. One final comment before we begin in earnest – it is a truism, but Parliament But, before considering the tax elements in further makes the laws by which we are required to abide. detail, it is necessary to step back and consider the law of contract (trust us, it is very relevant to the current The Distribution Centre
debate!). If I go into Starbucks (topical for other tax Now that I have had my offer accepted by Amazon reasons that we will comment about in a separate EU Sarl, Breaking Bad Season 4 (in case you have Milestone Tutorial) and order a Grande Soya Latte, forgotten), then needs to be distributed to me. I have the point of sale (i.e. the offer and acceptance that purchased a DVD from a Luxembourg company – that concludes the contract) is at the till. This is a matter is not in question. The auto-confirm email I receive from of well-established contract law. Similarly, if I walk 100 Amazon and my receipt states clearly that my DVD is yards down Piccadilly to Boots and pick up a packet “Sold by: Amazon EU Sarl”. The DVD will be held in
of Zantac priced at £2.99 and take it to the till, I am one of the various warehouse facilities that Amazon making an offer to Boots to buy their product. Again, it is has in the UK, France or Germany. It is most likely the their acceptance of my offer that concludes the contract DVD that is shipped to me will be located in the UK warehouse facility as I am a UK customer, but that may These same basic principles of contract law apply to on-line businesses such as Amazon. The critical The UK warehouse facilities will likely be owned by question being, where is the contract concluded. In the Amazon’s UK subsidiary. However, just because the case of Amazon, when I log onto Amazon.co.uk (which order I have placed with Amazon EU Sarl is fulfilled by is a trading name of Amazon EU Sarl, registered to the UK subsidiary does not mean that the transaction the Luxembourg company) and purchase Season 4 of has a UK source (at least for tax purposes). The fact that Breaking Bad the mechanics are entirely the same. I am the DVD owned and sold by Amazon EU Sarl is located offering to buy the product sold by Amazon, the contract in the UK (at the UK warehouse facility) is irrelevant too being concluded by the Amazon EU Sarl webservers Some might argue that because I have bought a DVD The place of contract is crucial to the tax analysis. from a co.uk website, which is distributed to me by a The conclusion of the contract will determine whether UK company, this does (or ought to) mean that the sale Amazon EU Sarl is trading in or with the UK. If the should be concluded in the UK or more pertinently (in contract for Breaking Bad Season 4 is concluded in the the mouths and pens of various commentators) that the UK, Amazon EU Sarl will be considered to be trading in profit arising from the transaction must be taxed in the the UK for UK tax purposes and its profits will then be UK. Others might argue that Amazon EU Sarl is trading in the UK through the UK warehouse operation, or to put If, by contrast, the contract for Breaking Bad Season 4 it in tax parlance the warehouse is, in fact, a permanent is actually concluded by the non-UK Amazon EU Sarl establishment (PE) of the Luxembourg company. For tax
server accepting my offer to purchase, Amazon EU Sarl purposes, when a foreign company, such as Amazon EU is trading with the UK. By definition, and with over 100 Sarl establishes a presence in a foreign country, either years of case law to support this analysis, Amazon EU directly or via a third party, that presence (be it an office, Sarl does not have a taxable presence in the UK and its warehouse, place of management etc) can become a place of business or PE (taxable presence). If a PE does arise this means a proportion of the profits of the This simple analysis seems to have been largely ignored foreign company will be allocated to that PE and taxed in the current debate. The general premise seems to be that it’s easier to brand a large corporate a ‘immoral’ than consider the tax and legal principles that govern its In the case of Amazon EU Sarl and its UK warehousing facilities (that it either owns directly or via a UK
subsidiary) the critical issue is whether this amounts
to a UK PE such that some or all of Amazon EU Sarl’s
profits should be allocated to, and taxed in, the UK. The
answer to this complex question can be found in the
Luxembourg/UK Double Tax Agreement (DTA).
Article V of the DTA defines a PE and includes the So, whilst Breaking Bad Season 4 was sold to me by Amazon EU Sarl, the fact that the DVD was stored in the UK and delivered to me by a UK company does not mean the Luxembourg company’s profits are liable to UK tax. Quite the opposite. The double tax treaty the UK has concluded with Luxembourg, which is based on the OECD Model Convention, specifically prevents the double taxation of those same profits.
e) a workshop; f) a mine, quarry or other place of extraction of natural These elements, particularly the fundamental tax concepts that most countries have accepted and g) a building site or construction or assembly project adopted into domestic law, have been almost wholly which exists for more than six months.
ignored in the current debate. In our view, this means the debate is ill-considered and based on emotive, rather The basic starting premise of the DTA is that Amazon EU Sarl is a Luxembourg company and is therefore subject to Luxembourg tax. Only to the extent it has a PE in the UK should it pay UK tax. As the title suggests, the DTA is We hope that this document serves to illustrate Amazon’s designed to prevent double taxation of the same profits.
likely corporate structure. Because Amazon is an international, e-commerce business that has chosen to Article V(3) goes onto explain that the definition of PE headquarter its European sales centre in Luxembourg means that profits it generates from sales are taxed in Luxembourg. Luxembourg is the profit centre of a) the use of facilities solely for the purpose of storage, its operation whilst the UK, France and Germany are display or delivery of goods or merchandise belonging cost centres. The result, as one would expect, is not avoidance as we have been led to believe. b) the maintenance of a stock of goods or merchandise belonging to the enterprise solely for the purpose of If the naysayers are to have their way such that companies like Amazon are required to pay UK tax on c) the maintenance of a stock of goods or merchandise these transactions, not only will the law of contract need belonging to the enterprise solely for the purpose of to be changed but also UK tax policy and internationally recognised agreements and concepts such as double tax treaties and transfer pricing guidelines. This In terms of warehousing and fulfilment, Amazon as a would require a fundamental re-think of how global business could, of course, outsource this to a third party here in the UK. This would not alter the tax analysis as set out above. Amazon chooses to invest in the UK (take Without doubt this is a complex area of tax law. As the site at Rugeley, Staffordshire, an ex-mining town, always with tax, it reflects the trade-off between the that employs 1,500 people) so it can control the delivery promotion of economic development and the desire of products sold by the Luxembourg company. The to raise sufficient revenue to enable a Government UK business will likely be funded by the Luxembourg to function effectively. Yet aside from this technical trading company and the amount paid by Amazon EU balancing act, tax is also a highly emotive topic not least Sarl for the services performed by the UK operation will because we are faced with a global financial crisis that be similar to what Amazon would have to pay a third means Government spending is falling in correlation to party. That is to say, the related party transaction will be benchmarked against open-market comparables to ensure the right price is paid. This is a fundamental Our biggest irritation is that the current debate lacks principle of transfer pricing to which all companies must balance and intellectual rigour. Little or no thought seems to have been given by the various MP’s and ‘commentators’ as to the economic outcomes that might result as a result of shifting the tax balance to ensure it is sufficiently UK centric. Were they to follow their logic through to its seemingly inevitable conclusion they may reconsider their position. This Milestone Tutorial is an attempt to explain how the current UK tax rules apply to an international business and why it would be very difficult to amend these. In our view, the UK tax system is in dire need of a rethink. However, if we do want to change UK tax policy and legislation, we need a real debate, one that is sensible and well informed on all relevant aspects. In the absence of this, the debate is not about tax but simply about (misplaced) immorality or fairness. This cannot be right.
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