Morrissey Central "I DON’T KNOW WHY MY MOTHER IS DEAD" (August 23, 2020)

I DON’T KNOW WHY MY MOTHER IS DEAD

“Following a stroke, her recovery was remarkable.
She had three extensive head-to-toe examinations by the NHS who could find nothing amiss.
Four days following the third all-clear examination I was told that my mother had three weeks to live.
Nine days later she had withered and died without any attempt by the NHS to save her life.
Once the NHS waves you off with paracetamol, get ready to meet your maker.
The official cause of my mother’s death was not the trendy and unquestionable “covid” - but, instead, cancer of the gallbladder … which had gone undetected by the NHS during their three thorough investigations.
How I wish to all gods that my mother had expressed no faith in the NHS.
She might still be alive today.”

Morrissey
23 August 2020.


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Media item:
 
You are right that it was not new legislation but what was brought in on April 2019 was a new withhold tax related to a much wider scope. Prior to 2019 the withhold had a very narrow scope and didn't cover an awful lot and was not bringing them money as they wanted it to.

The whole point of the new tax was as you say digital formats which is where the majority of sales come from these days and have done for a long time. Non digital again as I have gone through is dealt with by the record company and isnt directly related to income tax.

But the key point which you still miss is that it still doesn't apply, and has never done, when the company is based in a country that has a Dual Tax agreement.

It's real objective is to prevent the movement of royalties to countries with which the UK doesn't have a Dual Tax Agreement and many of those are countries have very low taxation so it is at attempt to stop tax evasion.

An example of this is when thinking about someone who buys something off iTunes in the UK. The royalty is received by Apple currently in Ireland. Ireland and the UK have a DTA so the UK can not withhold royalty tax. However what they are targeting is instances where if that royalty in Ireland was then forward paid to a company in say Brazil. Brazil does not have a DTA with the UK so it is then argued by the HMRC to be a payment direct to Brazil and then they will withhold the royalty tax.

In the scenario we are talking about if Apple transferred the royalty to a company which owns the copyright for the purchase to say Switzerland or Ireland then because they have a DTA the HMRC would not withhold the royalty tax. It would then be up to the company to pay the tax according to the tax rules in that country, not the rules of the UK and that generally will result in a lower tax liability and it wouldn't come into the UK.

This is the long running grievance people have with Apple for example. They make huge amounts of money on iTunes and app store sales and streaming fees but they don't go into a UK company account. They go into an Apple Irish account and the Irish government gives Apple a preferential tax benefit where they save huge amounts of money annually on their tax bill. But because there is a DTA set up the UK can not withhold tax.
Wtf is a ‘dual-tax agreement’. Do you mean a ‘double-taxation agreement’? Shut up and learn something!
 
It would be completely unwise and not really possible to operate such a high income company as a sole trader.

Sole trader means there is no limited liability and if things go wrong someone can not only lose the money within the company but also all assets of the company and all personal assets such as all property and then lead to bankruptcy.

Because of the increased risk of dealing with sole traders most industry clients will not do business with sole traders and will only deal with limited liability entities.

The other issue is tax liability. The tax liability for a sole trader is far greater than within a limited company because all income is taxed as income.

So all income above £50k would mean a 40% tax liability. If it goes above £150k then tax goes up to 45%. Also for every £2 above £100k income £1 is taken off the personal tax free allowance. When it reaches £125k there is no personal allowance.

Compare this to a limited company where the tax paid would be corporation tax which is currently 19%.

No one in the right mind with this kind of income would operate as a sole trader and would more than likely not be possible and the risks are personally great.

All my clients will not deal with a sole trader. They will only pay a limited company because of the risks involved. Sole trader is good for lower income businesses.
No you can’t ‘compare ‘ income tax rates with corporation tax rates. How are you going to extract the profit without additional tax, ie so that you can compare like for like ? I hope your ‘clients’ dismiss you for negligence ASAP.
 
It is liable. The treaty allows for a relief tax application but it's more for estates.

wow. you are talking rubbish again.

the whole point of a Dual Tax Treaty is that someone can not pay tax twice between two countries. It is the whole reason why Apple get away with making huge amounts of money of sales in the UK but dont pay tax on them because they are paid in Ireland.

relief tax application! You really should stop trying to understand this stuff by googling. It has nothing to do with "more for estates".

Straight from the HMRC detail on the Withholding Tax for you for the countries we are talking about:



[TD valign="top"]WHT%[/TD]

[TD valign="top"] Royalties [/TD]



[TD valign="top"]Non-treaty territories[/TD]
[TD valign="top"]20[/TD]


[TD valign="top"]Ireland, Republic of[/TD]
[TD valign="top"]0[/TD]


[TD valign="top"]Switzerland[/TD]
[TD valign="top"]0[/TD]


[TD valign="top"]United States[/TD]
[TD valign="top"]0[/TD]


[TD valign="top"]Cayman Islands[/TD]
[TD valign="top"]20[/TD]


So payments to a country with no Dual Tax Treaty will have 20% withheld on royalties.

Ireland because it has a DTT with the UK gets 0 withheld as does Switzerland and the USA.

I added in Cayman Islands as an example of a country often historically used as a tax haven and with no DTT so that has 20% withheld.

What your posts show is the whole style of how you get your information not only within this discussion on tax but with all your postings when you state things as facts but in reality they are far from facts. You misinform on here constantly and base alll your stated facts on snippets of googling and opinion or what you would like the fact to be.
 
Wtf is a ‘dual-tax agreement’. Do you mean a ‘double-taxation agreement’? Shut up and learn something!

you keep banging on and clinging to terminology. This isnt a legal document. It is referred to by many names. I am not quoting the HMRC page. Shows I am not getting this stuff from Google doesn't it if I am making mistakes with the actual name of it?

I have referred to it as a dual tax agreement, a dual tax treaty.

You are saying that doesn't exist and it is called a double taxation agreement!

Wow

You do realise that dual and double amount to the same thing?

Doh
You really are grasping now aren't you.
 
No you can’t ‘compare ‘ income tax rates with corporation tax rates. How are you going to extract the profit without additional tax, ie so that you can compare like for like ? I hope your ‘clients’ dismiss you for negligence ASAP.

what are you on about ffs.

I was showing that as a sole trader he would pay considerably more tax than under a limited company which is absolutely true.

As a sole trader all income is taxed under PAYE so in his case would be taxed at 45% with no personal allowance. So for every £1 he earns he would lose 45p.

Under a limited company the company income would be taxed at a corporation tax rate of 19% and not all income because all companies offset expenses against income and people claim expenses on lots of things depending on what the industry and company nature of business is.

Then he would pay himself a salary as a director which would be set at a level that does not cause a 40% tax lability.

Then he would get paid shareholder dividends which again would be structured to come out of the company at scheduled times to make it tax efficient.

There are many ways to get money out of the company to avoid high rate tax legally. The majority of the income can stay as retained profit within the company bank account without needing to be taxed personally until needed. It is only when it is removed from the company as dividends that it is subject to income tax and if done correctly would keep high rate tax levels at a minimum.

If this is all done within a country that has low corporate tax levels and income taxation such as in Switzerland then the amount of money saved compared to a company in the UK would be significant and obviously considerable more efficient than being a sole trader which no one with a large income such as this would ever do. Maybe your painter and decorator or your electrician but someone with a net worth of around £40 million never aside from the fact he has to interact with major companies such as record companies, management companies, and employees all of which means he would need the ability for a PAYE structure within the company and also most of these companies if not all are not going to do business with a high risk sole trader model. I wouldn't.
 
No you can’t ‘compare ‘ income tax rates with corporation tax rates. How are you going to extract the profit without additional tax, ie so that you can compare like for like ? I hope your ‘clients’ dismiss you for negligence ASAP.

to make it very very simple for you as a very basic example: (but in reality is more complex than this) but just for illustrative purposes:

Payments to Mr M in a year = £1 million (just using this as an example, I am not saying that is what it is)

As a sole trader income tax and National Insurance on that using each level of tax banding would be £435,000

With a limited company the corp tax would be £190,000 but that is a high level and in reality it would be a lot less because a percentage of the £1 million would be stated as expenses so that would not be taxed under corporation tax. As a very rough guide if £400k was stated as expenses for financial services, office costs, transport, crew, lighting, venue hire, artwork, hotels, insurance etc etc then that would reduce the corp tax to £114,000 and this is very conservative. If he pays people salaries and other costs it would also be different so it is just an example and a very simplistic one.

Then he could just pay himself £40k a year salary which would stay below high rate tax and then if he wanted more he could take that when he needs it as a dividend but he could also keep those below the high rate tax over the year. Any money he doesn't need to spend can remain within the company as retained profit and not be subjected to income tax which is not possible as a sole trader.

The tax benefits of working within the limited company are significant aside from the limited protection it guarantees. No person with this kind of wealth is going to set up a sole trader model that could put all of his personal assets at the reach of debtors. Never in a million years.
 

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