From the recently published Oxford report on UK Corporation Tax, Ritchie draws the following:
Within each sector there is evidence that, as a proportion of trading profit, the tax liabilities of the largest 100 companies are generally lower than for other companies.
He then concludes the following:
In other words - there is compelling evidence of systematic tax avoidance, because large companies should be paying tax at 28% and are actually paying it at less than the 21% due by small companies but we must not, Oxford says (returning to its normal apologist style) draw any conclusions from this - a point on which I fundamentally disagree with Mike Devereux, as ever.
This is, dare I say it, in fact nothing of the sort. It's compelling evidence, if anything, of comprehensive, undiluted Ritchiebollocks. Companies pay tax based on their taxable profits, not their financial reporting profits. While the former is derived from the latter, there's simply no reason for the country's largest companies to have similar sorts of adjustments to smaller ones.
Of course, accounting sort of takes care of this via a concept known as 'deferred tax'. Where the way an item is treated for tax and accounting is the same, but the periods in which it is recognised are different, 'deferred tax' is recognised to make the overall tax charge mimic the accounting entries, even though the actual payments may take place in different periods. The Oxford report doesn't really make it clear which 'tax charge' they are using, but I'm presuming they've taken current + deferred tax.
But there's another big problem with Ritchie's claim. The Effective Tax Rate in the Oxford report is based on EBIT , earnings before interest and tax. However, interest is an allowable deduction for corporation tax. So to the extent that companies have net interest payable, it will depress their effective tax rate, because the interest won't have been deducted in EBIT but will be an allowable deduction for tax purposes. The report explains why these data must be approached with caution. Of course, Ritchie doesn't think that these warnings apply to him, or he thinks that any discrepancies are ex ante evidence of tax avoidance.
This is pretty criminal stuff from Ritchie. Virtually every time he gets the chance, he tells us that Mike Devereux is a totally discredited academic. Yet here, because Devereux has provided some information with which he agrees, Ritchie has cherry-picked it to serve his own devices. Unfortunately, he's then chosen to compare apples (taxable profit) with pears (accounting profit), resulting in a nonsense analysis.
Filed under: Other blogs, Taxation with tags centre for business taxation, deferred tax, idiots, interest, michael devereux, oxford university, richard murphy
4 Comments »