By Paul Hannon, Timothy W. Martin and Sam Schechner
LONDON -- The U.K. government said it would move ahead with
plans to introduce a new tax targeting revenue generated locally by
large tech firms, setting the country on a path to become the first
developed country to roll out such a "digital" tax.
The new tax is still subject to final rule making and won't
start until 2020. Still, it comes as dozens of other countries are
contemplating new levies on digital services sold by companies such
as Alphabet Inc.'s Google and Facebook Inc. These governments are
hoping to capture more revenue from digital services as economic
activity increasingly shifts online.
The U.K. treasury chief, Philip Hammond, said Monday the tax
would only target large, profitable companies, with global revenues
of at least GBP500 million ($640 million.) The new levy would
target 2% of such a company's revenue in the U.K. Mr. Hammond said
it could eventually raise some GBP400 million annually.
The tax would be levied on activities linked to U.K.-based usage
of services like search engines, social media platforms and online
marketplaces. The tax was one of a series of fiscal measures
disclosed as part of the government's annual budget.
The Office for Budget Responsibility, the U.K.'s fiscal
watchdog, said that the Treasury's estimate of how much tax the new
levy will raise is highly uncertain. Among the questions as yet
unanswered about the new tax's structure are whether it will be
deductible against corporation tax, for instance. The watchdog also
flagged a range of ways the new levy could affect corporate
behavior as companies seek to minimize any liability, such as by
reclassifying revenue as income not covered by the tax.
Still, the OBR said it is also possible the digital-services tax
could prove a bigger money-spinner for the Treasury than its
preliminary estimates suggest, given that online activity accounts
for a growing share of the overall economy.
For giants like Alphabet, Amazon.com Inc. and Facebook, the U.K.
tax would amount to a relatively small sum of additional tax. But
it represents the first concrete step among several governments
globally to increase the tax burden of these and other large,
global tech-services companies.
The effort comes amid a yearslong backlash among governments,
particularly in Europe, against companies that critics say aren't
paying their fair share of taxes.
Opponents of digital taxes, which include lobbyists for
multinationals and countries with large amounts of exports, say a
patchwork of new rules that vary by country will hurt smaller
companies. They say the initiatives could lead to double taxation
of corporate profits, which will stifle international trade and
discourage investment.
The tech industry opposes the proposals. On Monday, after the
U.K. announced its planned tax, the Information Technology Industry
Council, a Washington, D.C.-based lobby group that represents tech
companies including Google and Facebook said that "imposing a
digital tax could create a chilling effect on investment in the
U.K. and hinder businesses of all sizes from creating jobs."
Amazon and Alphabet declined to comment on the new tax. Facebook
and Apple didn't immediately respond to requests for comment. All
four companies have said in the past, amid criticism of their tax
practices, that they pay their fair share.
The U.K. first said it had justification for a new tax in
November 2017, arguing users of digital services help make the
product that tech companies sell to advertisers and other
customers. That principle has influenced the rest of the European
Union, which is working on its own tax proposal.
Since launching a broad effort to overhaul the system for taxing
companies that operate internationally in 2013, developed-country
governments have been divided on whether to introduce new levies
that specifically target digital companies or to treat digitization
of the economy as a process that requires a more broad-based
response. The Organization for Economic Cooperation and
Development, which oversees international tax negotiations, hopes a
compromise can be reached by 2020.
Mr. Hammond said that while a global agreement "is the best
long-term solution," progress has been "painfully slow." The U.K.
said its new tax would only be in force until a global solution is
found, but Mr. Hammond said "we cannot simply talk forever."
Inspired by European Union proposals to impose a tax based on
the revenue of tech companies rather than their profit, South
Korea, India and at least seven other Asian-Pacific countries are
exploring new taxes. Mexico, Chile and other Latin American
countries too are contemplating new taxes aimed at boosting
receipts from foreign tech firms.
Such taxes, which are separate from the corporate income taxes
many companies already pay, are broadly known as digital taxes and
could add billions of dollars to companies' tax bills. They seek to
impose levies on digital services sold by global companies in a
given country from units based outside that country. In some cases,
the proposed taxes target services involving the collection of data
about local residents, such as targeted online advertising.
Europe is the largest overseas market for many tech companies,
and the EU estimates that its proposal would bring in about EUR5
billion ($5.7 billion) annually. But digital taxes could eventually
take a bigger bite in Asia, where growth is faster and there are
many more internet users.
At the heart of the debate is the question of where tech giants
should pay their taxes.
Under international tax principles, income is taxed where value
is created. For tech companies, that isn't always clear. Services
including advertising and taxi reservations are now often delivered
digitally from halfway around the world, by companies that pay
little income tax locally.
U.S. tech companies often report little profit, and therefore
pay little income tax, in the overseas countries where they sell
their digital services. That is because customers in those
countries are actually buying from a unit based elsewhere, often a
low-tax country. The in-country unit is tasked with marketing and
support, and the overseas unit that actually makes sales reimburses
the local unit for expenses, leaving little taxable profit.
Under growing political pressure, some tech companies, including
Amazon.com., Facebook and Google, have recently started declaring
more revenue in countries where they do business. But they also
declare more expenses locally, which could offset much of that
additional revenue.
The U.K. tax and the other global proposals put pressure on
countries with large economies -- including the U.S., which last
year imposed a new minimum tax on U.S. multinationals' overseas
profits -- to arrive at an agreement about how to tax the digital
economy. The OECD has been leading international talks with the
goal of reaching a consensus by 2020.
Pascal Saint-Amans, the head of the group's tax-policy center,
said the proposals create an incentive to move more quickly. "We
understand there has been some frustration, and there is a
political urgency," he said. "We cannot ignore it."
On Thursday, Treasury Secretary Steven Mnuchin expressed concern
over "unilateral and unfair" tax proposals aimed at U.S. tech
companies and urged his overseas counterparts to work within the
OECD on a global plan.
Write to Paul Hannon at paul.hannon@wsj.com, Timothy W. Martin
at timothy.martin@wsj.com and Sam Schechner at
sam.schechner@wsj.com
(END) Dow Jones Newswires
October 29, 2018 15:02 ET (19:02 GMT)
Copyright (c) 2018 Dow Jones & Company, Inc.
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