Google uses Article 5 of the
UK/Ireland DTA to justify its tax arrangements, but is there room
for review, asks Andrew Goodall
Amid the controversy surrounding the tax affairs of Google and
other US-based multinationals there has been relatively little discussion
of the Organisation for Economic Cooperation and Development's (OECD)
work to plug 'gaps' in the international tax system. The OECD warned
in February that legal but 'aggressive' tax strategies employed by
some multinationals were eroding the tax base of many countries and
that the integrity of the system was at stake; at the same time, it
cautioned against unilateral and uncoordinated action by individual
countries, which could result in the risk of 'multiple' taxation and
have a negative impact on investment and employment.
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