I never suggested a global brand doesn't make any profit in the UK - so get that notion out of your head!!



You would admit a brand has some value - so how would you suggest the value of that brand is financially recovered by those entities that benefit from using it?



If Apple in the UK wasn't called Apple but sold the same products do you think it would be as succesful - of course it wouldn't. It is the brand and the perception of what the brand delivers that generates the revenue. So do you think the UK firm should be immune from any costs that enhance that brand globally from which they directly benefit.



Are you suggesting that all these costs should be born by the HQ. Perhaps there needs to be a new IFRS that sets out a mechanism for calculating this brand licencing e.g. sales as a % of global turnover = % of licence fee to pay.

No I won't, the entire point is they make MAMMOTH profits, but pay zero tax on these profits. How did that escape you?





Why are you harping on about brands? The point is, if your brand is so valuable, why sell it? The answer is you don't "really" sell it, you pretend to sell it, to a group company in a minimal tax jurisdiction, and artificially make all your "profits" there instead of where they are actually earned.





Look, you aren't a stupid person, so why are you trying to construct straw man after straw man? Why not instead just deal with the actual point, which is paying tax to the UK on profits made in the UK?





No, we all know that a company would never really give away its brand only to licence the use back at astronomical annual rates in perpetuity. If they want to do that between group members for their internal accounts - fine! It just is not or never should be a tax deductable expense. Because it is not a payment made for genuine business purposes, it's a blatant tax scam and nothing else.



Your schoolboy error is in talking about "costs". If you don't GIVE AWAY your brand then you won't have ANY licence costs. These licence costs are just artificially created and for no other reason than avoid paying tax.

They pay zero tax on those profits in the UK - they do pay huge amounts of tax just not here.



You are not stupid - they are not selling their brand they are licencing the use of it - is that really such a difficult concept for you to grasp?



The straw man is what constitutes profits and what actually constitutes cost. In your mind its just COGS plus expenses - if only it were so simple even for UK only companies



I ask again how is the HQ meant to recover legitimate costs relating to investment in the name/brand that the overseas subsiduary will receive benefit from? Perhaps you would find it more palatable if they included it in higher HQ recharges - it amounts to the same cost.

You are dropping tons of mud into clear waters.



You somehow fail to grasp that owning the name rights is what an owner does. It costs them nothing. If I invent the name "Aardvark Koffee" and register it then that's it. I pay nothing ever. To anyone. It is mine. Free.



If I make loads of money, I pay tax on the profit.



I should not be allowed to wipe out that profit by artificially creating a situation where I now have huge "licence fees" to pay for what was entirely mine before I gave it away.



It is nothing at all to do with LEGITIMATE COSTS. I don't quite know what legitimate costs being called Aardvark Koffee could conceivably incur but if there were any then fine. But in the example I am using, the cost is NOT "legitimate", it is an unnecessary and artificial dodge to transfer taxable profits from where they are made to somewhere where the tax rate is minuscule.



And you think that's legitimate?

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