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Wednesday's Top 10 with NZ Mint: Apple's effective tax rate of 0.06% in Ireland; Just print me a pizza; 'Hallelujah, it's raining Yen!; Solar panel settlement may hike prices; Dilbert

Wednesday's Top 10 with NZ Mint: Apple's effective tax rate of 0.06% in Ireland; Just print me a pizza; 'Hallelujah, it's raining Yen!; Solar panel settlement may hike prices; Dilbert
<a href="http://bit.ly/107VHl0">Five key reasons people buy gold and silver</a>

Here's my Top 10 links from around the Internet at 1 pm today in association with NZ Mint.

As always, we welcome your additions in the comments below or via email to bernard.hickey@interest.co.nz.

See all previous Top 10s here.

My must read is #2 on raining Yen. Hallezlujah. 

1. Apple in the tax hunt firing line - The big business news over the last 24 hours or so has been the explosive US Senate report detailing just how clever Apple is at avoiding paying its taxes overseas (in places like New Zealand).

Here's the full senate sub-committee report.

It's a cracking read that's bound to make any normal taxpayer's blood boil.

It's symptomatic of the pathologies inherent in many large multi-nationals around taxation, executive salaries and long term employee relations.

Do they realise actions like this are forcing governments to cut funding to kids, schools and hospitals?

Do they realise it will eventually hit their own customers?

This will be a theme governments, consumers and voters will return to time and again over the years to come.

Here's Quartz with the first 3 of the 7 craziest ways Apple avoids paying its fair share:

1. Almost all of Apple’s foreign operations are run through an Irish company with no employees. The company told investigators that it lost all records concerning why Apple Operations International was originally set up in 1980, and why all of Apple global sales go through it. You might have a few ideas why if you keep reading.

2. Apple pays 2%—or less—in corporate income tax in Ireland. The already low-tax country gives Apple special treatment with a negotiated 2% income tax rate. But that’s just the top-line number: Between 2009 and 2011, one Irish subsidiary, Apple Sales International, earned $38 billion and paid $21 million in taxes, for an effective rate of .06%.

3. Apple Operations International, which provided 30% of Apple’s worldwide net profits from 2009 to 2011, doesn’t pay taxes anywhere. This move is devilishly brilliant: The US decides if it can tax you based on where you incorporate your company. Ireland decides if it can tax you based on the location of the people managing the company. So if you incorporate a subsidiary in Ireland, and manage it from the US, you don’t (so far) have to pay taxes in either country. And that’s exactly what Apple has done, not filing a tax return for AOI anywhere in the world in the last five years.

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2. It's raining yen, Hallezlujah  - Satyajit Das explains here at Economonitor how the currency wars now sweeping from America and Britain to Japan and soon on to Europe are just part of a wider economic contest.

New Zealand still naively believes its a fair contest.

Currency conflicts are merely skirmishes in the broader economic wars between nations. Most developed nations now have adopted a similar set of policies, to deal with problems of low economic growth, unemployment and overhangs of high levels of government and consumer debt.

In a shift to economic isolationism, all nations want to maximise their share of limited economic growth and shift the burden of financial adjustment onto others. Manipulation of currencies as well as overt and covert trade restrictions, procurement policies favouring national suppliers, preferential financing and industry assistance policies are part of this process.

Central banks are increasingly deploying innovative monetary policies such as zero interest rates (“ZIRP”), quantitative easing (“QE”) and outright debt monetisation to try to engineer economic recovery.

Artificially low interest rates reduce the cost of servicing debt allowing higher levels of borrowings to be sustained in the short run. Low rates and quantitative easing measures help devalue the currency facilitating a transfer of wealth from foreign savers, as the value of a country’s securities denominated in the local currency falls in foreign currency terms.

The policies also force the cost of economic adjustment onto other often smaller nations especially emerging countries, via appreciation of their currency, destabilising capital inflows and inflationary pressures, for example through higher commodity prices. Given that emerging markets have underpinned tepid global economic growth, this risks truncating any recovery in developed nations.

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3. The Eurozone's woes in one chart - Courtesty of Ed Dolan at Economonitor.

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4. Yum yum - Quartz looks at moves to make food using 3 D printers and food powder.

New Zealand will be rich, given we produce so much milk powder! HT Dave Pell via emai

Anjan Contractor, a mechanical engineer with a background in 3D printing, envisions a much more mundane—and ultimately more important—use for the technology. He sees a day when every kitchen has a 3D printer, and the earth’s 12 billion people feed themselves customized, nutritionally-appropriate meals synthesized one layer at a time, from cartridges of powder and oils they buy at the corner grocery store. Contractor’s vision would mean the end of food waste, because the powder his system will use is shelf-stable for up to 30 years, so that each cartridge, whether it contains sugars, complex carbohydrates, protein or some other basic building block, would be fully exhausted before being returned to the store.

Ubiquitous food synthesizers would also create new ways of producing the basic calories on which we all rely. Since a powder is a powder, the inputs could be anything that contain the right organic molecules. We already know that eating meat is environmentally unsustainable, so why not get all our protein from insects?

5. Trade war stand-down - The New York Times reports Europe and the United States look settle with China over their anti-dumping complaints against Chinese solar panel suppliers. 

This is good news for those worried about the beginning of some sort of Smoot Hawley trade wars. It's not so good for environmentalists who want really cheap solar panels.

The plan that is starting to take shape would essentially carve up the global solar panel market into a series of regional markets. It would sharply raise the price of solar panels exported from China, the world’s dominant producer, by requiring Chinese companies to charge more while limiting the total number of solar panels they could ship.

In exchange, Chinese companies would no longer be charged steep taxes on their exports of solar panels. The United States is already collecting tariffs totaling about 30 percent while the European Union is expected to impose similar tariffs of about 50 percent on June 5, and may backdate them to March 5.

Parallel decisions by the Obama administration and the European Union to separately negotiate high prices for imported solar panels may prove unpopular among environmentalists. Some environmental groups are already upset that the tariffs have made solar energy less affordable, making it less competitive with more polluting fossil fuels.

6. The Great Chinese Housing Boom - Here's the Federal Reserve Bank of St Louis with a research note on the scale of the credit-fueled housing boom in China.

Let's hope the US Federal Reserve doesn't do a similar study of New Zealand house prices...our price to income multiples are not much better in some places.

Housing and land prices in China have increased continuously and dramatically for the past two decades. In fact, housing price growth has significantly outstripped income growth. Current housing prices are roughly 11 times annual income; in large cities such as Beijing and Shanghai the price-to-income ratio is as high as 23 to 1.1 By comparison, Tokyo house prices were 15 times income and U.S. house prices 5 to 6 times income when the Japanese and U.S. housing bubbles, respectively, burst in 1990 and 2006. Rapid price growth, large price-to-income ratios, and high vacancy rates (between 25 and 30 percent) suggest the possibility of a bubble.
 
The top chart compares key facts for the Chinese and U.S. housing booms and the bottom chart compares the recent mortgage debt as a share of gross domestic product for both. While in both cases nominal house prices increased by close to 50 percent over a 5-year period, the differences are striking. The U.S. housing boom reflects overconsumption and overborrowing, whereas the Chinese housing boom reveals large investment in construction and apartment holdings. Most of the “vacant” Chinese homes have been sold to private owners but are being held as investments alongside multiple other homes.

7. Europe faces a lost decade - So says incoming Bank of England Governor Mark Carney in this Telegraph piece. 

In words that will underline his status as a monetary activist and fuel speculation that he will try to relaunch quantitative easing (QE) when he arrives in the UK, Mr Carney applauded Japan’s “bold policy experiment” to boost dramatically its own QE programme.

He said: “Europe can draw lessons from Japan on the dangers of half measures... Europe remains in recession. Deep challenges persist in its financial system. Without sustained and significant reforms, a decade of stagnation threatens.”

8. Say what? - Australia's superannuation industry wants a lump sum tax put on withdrawals from its schemes, the Sydney Morning Herald's Michael Pascoe reports. 

At first, it might seem a “very brave” decision for the super industry itself to want a tax on lump sum withdrawals, or a cynical soul might suggest it is self-interest at work for the big super funds wanting to keep their hands on individuals savings and thus continue to clip a bigger ticket. ASFA argues that it is necessary to encourage individuals not to run their retirement savings.

“The primary purpose of superannuation is to provide financial security in retirement. This purpose is not currently being achieved with any certainty as there are many potential leakages that are a cost to the system's integrity and the taxation concessions provided."

ASFA says the leakages include both using superannuation benefits too slowly for estate planning purposes and using them too quickly. In the latter case, the result is having insufficient protection against the financial consequences of living a long time or longer than most other people and “excessively running down retirement savings when they become available to either fund excessive consumption and/or debts that were built up in the lead up to retirement in the knowledge that a lump sum would be available”.

9. The new normal for coal - Bloomberg reports Indonesia's second biggest coal producer saying the 'new normal' for the coal price is now US$100/tonne, half what it was in 2008. Someone should have told Don Elder. Perhaps his board, or his minister. Just someone. 

10. Totally Jon Stewart on the US health system's need for a decent computer system

(Updated with quotes)

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50 Comments

#4

Sorry, luv, the cockroaches have gotten into the Ingredient Store - again - and their droppings have clogged our Meal Preparation Printer.  Again.

 

Why don't we just catch and fry a few of Them - after all - insects are Such Good Food and we Do know exactly What they've been eating - and disintermediate our Food Chain?

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I thought it might have been that joke about Krugman...............

 

Krugman orders a pizza. Guy asks if he wants it cut into 6 or 8 slices. Krugman says, '8 please. I'm very hungry today.'

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#1 Any business will arrange its affairs to minimise its tax obligations. That is their duty to their shareholders. The guilty parties here are Governments that come up with offerings to corporates so they can collect some tax on activities that had nothing to do with them at the expense of tax payers in countries where the economic activity is really taking place.

It is up to Governments to come up with ways to stop businesses jurisdiction shopping.

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Isn't Apple the biggest company on earth?  Why didn't someone at the US IRD say "hey guys, did that Apple company pay tax this year..."

 

How do you miss that?

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Because they will pay about US$7 Billion to the US IRD in fiscal 2013.

 

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Item 1 in my calendar for tomorrow, ask my accountant to re-incorporate my company in Ireland. 

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It is not true that any business can engage in what is effectivley transfer pricing.

Small coffee shops do not have the resources available to setup Irish subsidaries with a Dutch domiciled back office, through which to licence I.P.

Companies the scale of Starbucks do, and then undercut the local smaller rivals, putting them out of business.

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The US authorities have developed a Tax Code that allows US companies with off-shore earnings to avoid paying tax. That amounts to a straight out subsidy. Yet look at item #5. Guess who is complaining. Yep. The Norte Americanos. Good for goose. Good for gander.

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#5 - Anyone...  Why arn't solar panels common in NZ?  Is it not sunny enough?  Or is it cheaper to just buy power off the grid?

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The New Zealand Government can be accused of protecting its patch and the value of its assets while flogging them off. Actively discouraging the proletariat from developing any thoughts of independence from the ruthless monopolists.

 

Did you see that schedule of power prices throughout nz that David Chaston put up yesterday? a real jaw dropper. Gives you an idea of why they don't want too many solar panels in nz

 

And you can assume the power generation companies will have protection agreements in place guaranteeing them exclusivity for at least 10 years. And they won't have to provide economic Feed-in-Tariffs either. You betcha.

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Did you see that schedule of power prices throughout nz that David Chaston put up yesterday?

 

No I didn't - link pls?

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I saw it late last night - cant remember which article it was in - just browsed through most of yesterdays and couldnt find it.

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Big Energy Attacks Aussie Solar Households - report by Energy Matters
   
An article published in the Sydney Morning Herald has raised the hackles of small scale solar panel system owners and solar businesses in Australia.
 
The article states new research by the Energy Supply Association of Australia (ESAA) shows solar owners are avoiding network charges of $340 million a year and "feed-in-tariff'' schemes are adding $680 million a year; the costs of which are being met predominantly by non-solar households.

 

The (lobby group) ESAA, whose membership includes AGL, Origin, EnergyAustralia and other 'Big Energy' players, has not yet made the study publicly available from its web site. However, the SMH article fails to make mention of the many benefits and potential benefits of small scale solar to the wider community aside from a couple of lines toward the end of the article that really only just scratch the surface

http://www.energymatters.com.au/index.php?main_page=news_article&article_id=3746&utm_source=NewsletterMailingList&utm_medium=email&utm_campaign=EM130522C

http://www.energymatters.com.au/

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They use coal. Go figure. 85% for Aus, 90 for Victoria. There's some sweating going on, probably. Not just the big existing players, but the coal industry.

 

Ever been through Lithgow?

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"additional costs that have been attributed in part to the "gold plating" of electricity infrastructure"

gris.org is covering a similar thing in the USA...it paid the utilities to put excessive infrastructure in...

http://grist.org/climate-energy/utilities-for-dummies-how-they-work-and…

They want to sell energy, to make a tidy profit, simple. They have bought an asset that they expected a return on only to find that its being used less than their calculators said to expect, so their debt is more of a problem...more fool them.  Now I agree that there needs to be a National infrastructure so there needs to be a charge to cover it, the Q is what will that charge be a flat amount per day.  

regards

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Big Energy emulates Big Oil

The lobbyists are winning - again - the Powerful Few versus the Powerless Many

http://www.theaustralian.com.au/national-affairs/solar-price-rise-to-end-power-divide/story-fn59niix-1226650277855

 

What they never ever mention is that Big Oil and Big Energy currently receive $10 billion a year in government subsidies

 

psssst: post that URL into google.news gives full article for free

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H123 - that's an easy one.

 

Grid-parity is about $3/watt, and will only go up (competing in the energy/displacement field, cherry-picking of the best first, plus expectations of profit).

 

Panels can be bought for close to $1/watt, and I've heard of a container-load at 65c. That's enough of a difference, in anyone's language.

 

If you're already on-grid, though, it's probably not worth going off. In dollar terms that is; I'd still be happier no being beholden....

 

For greenfields building, it's a no-brainer. Off is cheaper - with the proviso that you stay away from heating - it's the energy killer.

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yep. $0.65c per watt. check out the alibaba chinese web site for prices per watt .. dont see how the US is claiming they're dumping. http://www.alibaba.com/countrysearch/CN/solar-panel-price.html

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 65c watt is the target for container lots at the moment PDK , and there is still significant downside. We haven't got close to the  real economies of scale in NZ.  Two of the brightest of my son's school friends became sparkies. At the time I thought it a waste of good brains. Now they are into this big time, absolutely on fire with passion for their work and everyone is wanting to throw venture capital at them.

Grid-parity is by no means a one way street. The Grid is about to come in for some serious competion from local co-operatives with serious nous and clout. 

It's not just panels either. Some of the solid fuel burning technology that is now available is stunning.  Observed Mr F examining a German unit last week with such intensity I felt a little miffed. Been a while since he looked at moi like that :)

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Chuckle. If I feel that way, I look at her as if she was a boat.   :)

 

Yes, I think we may be looking at the Telecom/NZ Post Mum and Dad suck-in all over again. The only difference is that our grid is largely renewable; so even if it became a dinosaur, it would still be a needed one.

 

good luck to those boys - we'll need their kind where we're going.

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Personally I think good trades is the way of the future, you get a good salary, can earn more if you want the hours and dont get much college debt to do it (if any).  Too many youngsters get a media studies degree (or similar rubbish) and 30k debt they will never pay back quickly as they'll be countdown checkout workers.

regards

 

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so true .. we had a flood last year due to the roots of the council owned eucalytus trees getting into the storm-water pipes and breaking them. 5 council guys with a coupla trucks with massive "rooters" here at midnight .. sounded like a boeing 747 - back next day to clean up .. chatting away about jobs .. they were happy it's one job that can't be off-shored

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Regarding, sunny:

Total solar energy per square metre (not quite the same thing as direct sun best for solar generation, but easier to get figures on):

North Island: Mostly equivalent to Melbourne

Far south of the South Island: Still a lot better than Germany.

It is basically that the setup/ setup hassle costs in NZ make it generally not worth the amount saved (it isn't really a commodity setup plug-in product). And for those paying a lot due to high use, the lifestyle costs of not running electric heaters with the windows open is not a lifestyle change they want or need to make. For those using grid power highly efficiently, there are fewer needed lifestyle changes but the return on investment period is much longer.

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Cheers all.  I'll stay on the grid until the solar tech gets cheaper/better. 

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Interesting  - I'm nearly 10 years without a power bill. Total outlay (lights, wiring, switches, fittings, generator, batteries, micro-hydro, control) just over 5k. Running costs were $1/day petrol, now about 1/2 that.

 

It's already cheaper/better. Stay on-grid by all means, but investigate dual-element separate hot-water, from PV. You'll shake your head........ it's cheaper than solar water systems (counterintuitive, but there you go) by quite some margin

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I into my 3rd year without a bill .. but I'm grid tied and when the grid goes down my system goes down too. We had a total grid-black out for 6 hours about a month ago - on a brilliant sunny day - and my system goes down - is there any way around that?

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Could you link to or explain "dual element separate hot water from PV" please? cheers

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Iconoclast - yes, easy. A single panel (say 50watt - we ran our house on a 50-watter for several years), a single deep-cycle battery, and a separate LED low-voltage lighting system. Mobile, even (we use one standard-lamp, shift it around/plug it in - you can only be in one place at a time.

 

Learn to S - -- Yep. There are two elements in the one fitting. It screws into the same hex-hole that ordinary elements do. One is the ordinary grid (230) element, one is your solar one. On a sunny day, you can turn the grid one off. Too simple. The thermostat works on both.

 

Ecoinnovation have a whole lot of dual elements, I understand, and a person I know is looking at setting up a business installing them.

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# 4.  Pizza.  Best Pizza I ever had was the last rainy Sunday afternoon passing through Clyde.  Wonderful.  At the Clyde Bistro. Had a long chat to the man about his very large wood fired oven.

Not a 3D printer in sight.

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Of those of us in the IT industry the Irish tax system was hot news .. about 12 years ago.  It's hard to think of any large IT company I know that hasn't been doing it this way for years.

 

Personally I suspect the current wave of multinational hysteria is just a political stunt.

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#8.  The big super risk.

Expect to see more and more of this.  If YOU don't save it -- it's not really YOUR savings.

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Anyone who has ever participated in the "international business game" would realise the financial power and understand the significance of companies like Apple and Google and Facebook not paying tax. Shifting earnings to the Cayman Islands and Bermuda. Over time it is impossible for tax-paying competitors to compete in any meaningful way and survive at the same time.

 

The tax-paying entities become financialy weaker and weaker relative to their non-taxed counterparts, and eventually fail.

 

The same characteristic is being played out in the Auckland Property Market. Contrary to some who can't see it yet.

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You don't have to be international iconoclast.  Have a look at these huge busineses in New Zealand called 'charities'.  Who are mainly operators of very big government contracts and pay no tax.  These are rapacious operators ready to crush any aspect of competition. (including each other admittedly)  And will use any tearjerking means to get build their image.  - see the TV adds?  -

I don't see the charity in practice.  And from observation I see how they operate first in their own interest.    And being so proud of their own humbleness, they are capable of anything.  Give me a private operator any day.  Don't try to go up against these sharks.

Hundreds of millions of dollars in lost tax here.

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Here's the related article on registered charities who aren't required to be charitable;

 

http://www.stuff.co.nz/the-press/news/8688131/Flush-Kiwi-charities-failing-to-pay-out

 

The Government is $600 million out of pocket each year as the charities sector swallows $400m through income tax exemption and $200m in tax credit refunds, yet Cabinet decided against reviewing charity law last year through "fiscal cost" fears.

 

Labour's charity spokeswoman, Louisa Wall, and Christchurch charity expert Dr Michael Gousmett have slammed the lack of accountability in the multimillion-dollar, publicly subsidised sector.

 

Anyone who thinks we don't need a change of government needs their head read.

 

 

 

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And here's a great comment on that article;

 

Are we talking about the same government which wants to arrest those student loans defaulters when they return to Godzone? altogether owing some $400 million.......

yet the same government allows their supporters to get away with $600 million a year?

whatever next

 

(Spelling corrected)

 

 

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but to what? would labour be any better?  in some ways, yes, in others, well worse.

regards

 

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Well if we use John Key's measure of good governance - that being a return to surplus - well yes, they'd be much better.

 

All other things staying the same, fixing this single tax issue associated with charitable status would return a far greater surplus than what John is forecasting in 2014. He's promising a $75m surplus .. well this would add another $600m to that if the law were changed today (as Labour have indicated they would do). 

 

 

 

 

 

 

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No 1 - I would hardly think Apple pays any annual tax on profits in NZ due to the tax treaty with the US and how Apple is set up.

Is NZ missing out on millions or perhaps billions annually  from having these tax treaties in place?

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I have read parts of the NZ tax treaty with the US. Can't see how it results in what you are suggesting. But I am no expert on it. Would be very interested in the detail to back up your claim.

 

Post it, or send it through to me directly. david(dot)chaston(@)interest(dot)co(dot)nz

 

(Not doubting that Apple is shifting income (transfer pricing) to take advantage of the lowest tax rates offered - just would like to see evidence that they are using tax treaties to do it.)

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My wife just bought a new phone off apple.co.nz, its billed in eire...

Im sure there will be a reason for it...

regards

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best guess? no GST - did the invoice have GST? - all businesses doing business in NZ are required to render a GST invoice - GST included or not.

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DC - I would like to respond but keep getting cut off/timed out,

 

http://www.kurtinlaw.com/wp-content/uploads/2013/05/U.S.-Senate-PSI-Mem…

 

I suggest you read the memorandum. This is an extract  from the Executive summary.

"One of Apple’s more unusual tactics has been to establish and direct

substantial funds to offshore entities in Ireland, while claiming they are not tax residents of any jurisdiction. For example, Apple Inc. established an offshore subsidiary, Apple Operations International, which from 2009 to 2012 reported net income of $30 billion, but declined to declare any tax residence, filed no corporate income tax return, and paid no corporate income taxes to any national government for five years . A second Irish affiliate, Apple Sales International, received $74 billion in sales income over four years, but due in part to its alleged status as a non-tax resident, paid taxes on only a tiny fraction of that income."        
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by mist42nz 20 Feb 13, 4:04pm

Apologies notaneconomist, that's my fault. The editor keeps timing out on my initial posts so I kept them shorter, and proofread them second and third times after hitting the "save button" and filled out the remaining pieces.  I will find a better way of dealing with the timeouts. Thanks.

 

by iconoclast 20 Feb 13, 4:10pm
MIST: simple solution. compose your articles in notepad or wordpad first. check. proofread. Take your time. Then, copy and paste into interest.co.nz. save. 5 seconds. no timeout

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Apple pays 0.4% tax on it's NZ products- using the same Irish scheme.

http://www.nzherald.co.nz/business/news/article.cfm?c_id=3&objectid=108…

 

 

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Solar...

I have a 10KW ON-GRID system (so no batteries etc.).

The guys I used are flat out (and have taken on staff)!

In ChCh some homes are being built pre-wired for solar.

No one really trusts the NZ Goverment to change a lightbulb, so in some way this sheilds you from idiots... or worse from Privatised Energy Companies that WE ALL KNOW are going to hike prices as fast as possible.

Whats the problem? you not only help against the leccie bill but are saving the planet.

In Oz; in some areas, you cannot put a new ON-GRID system in as the leccie system can't cope (electricoty is SUPPOSED to flow from the producers to the consumers and it doesnt work very well when it flows back up).

 

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yeah - we had a Wwooffer here recently, who designs and installs megawatt-sized arrays in Aus.

 

They'll just have to get used to it - the old days of one generator being 'on the bike' controlling things by phase-timing, may be over. One way to get around that, would be for the houses to put their PV grunt into their HW cylinders, ex-grid. (dual elements are easy to do in the same hole, I'm told). That would slow the surge, give more adaption time.

 

Anyone here know Patrick Smellie? Introduced as an energy commentator, on The Panel. Is he actually a person who investigates energy matters, or? 

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I am visting relatives in Pennsylvania USA.  They just signed up for residential electricity on a 12 month contract at US$ 0.0736 per kWh (about NZ$ 0.0898 per kWh).  This is federally subsidised nuclear power (a la Three Mile Island).  That's about what I paid when I emigrated to Dunedin 19 years ago, if I recall correctly.

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Yeah I think thats about right.....7 to 8 cents, now its something like 23cents...one huge fiddle...

regards

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As many of you will be aware, a common way to avoid paying tax is to set your business up as a franchise. The franchisor is a brass plate in the Cayman Islands and the franchisee pays a high enough franchise fee to negate any profit and therefore pay no tax.

 

Why aren't such loopholes closed?

 

Follow the money.

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Because its hard to do so....I can understand there are legit reasons for how things are.  Sorting the legit reasons out v the legal scams is very hard, but I think voters throughout the world sowings signs of having had enough.  I mean as it stands that of course means NZ owned businesses where all the money stays in NZ are dis-advantaged, yet money staying here is exactly what we want to see IMHO. 

 

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