[HN Gopher] Netflix Europe offices raided in tax fraud probe
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       Netflix Europe offices raided in tax fraud probe
        
       Author : user20180120
       Score  : 309 points
       Date   : 2024-11-05 14:20 UTC (8 hours ago)
        
 (HTM) web link (www.bbc.co.uk)
 (TXT) w3m dump (www.bbc.co.uk)
        
       | orangepanda wrote:
       | Is a mini-series about this already greenlit?
        
         | 23B1 wrote:
         | yes but it was cancelled after becoming too popular
        
       | diggan wrote:
       | The meat:
       | 
       | > Last year, French media outlet La Lettre reported that until
       | 2021, Netflix in France minimised its tax payments by declaring
       | its turnover generated in France to the Netherlands.
       | 
       | > investigators are trying to determine whether Netflix continued
       | to attempt to minimise its profits after 2021.
       | 
       | Wasn't Uber or some other US company found doing something
       | similar? First they were found to be in violation of some
       | law/dodging taxes, said they'd fix it and later found to not have
       | done anything about it? Is that behavior perhaps more accepted in
       | the US than Europe?
        
         | kbolino wrote:
         | It's hard to accurately measure secretive crimes like this, but
         | the estimates seem to put corporate tax evasion by percentage
         | of GDP at either similar levels between the EU and US or
         | actually higher in the EU.
        
           | kranke155 wrote:
           | The EU is just as corporatist as the US. The corporations
           | just aren't as big, but they control their local/national
           | politics effectively.
        
         | yunohn wrote:
         | Literally _every_ single company that can afford to setup
         | things like tax transfer schemes, are actively evading taxes.
         | 
         | It's mind boggling how widespread it is, how accepted (legal)
         | it is, and how it will seemingly never be fixed.
         | 
         | https://www.somo.nl/the-netherlands-still-a-tax-haven/
        
           | diggan wrote:
           | > Literally every single company that can afford to setup
           | these tax transfer schemes, are actively evading taxes.
           | 
           | Yeah, but I think that's different than what happened in this
           | case with Netflix. Declaring earnings from one country in
           | another country is not just "tax optimizations" but straight
           | up illegal. It's not using/abusing legal loopholes like most
           | larger companies do, but going against the law.
        
             | yunohn wrote:
             | Honestly, I'm not sure. I find the premise of such tax laws
             | to be illogical at a basic level. There are apparently
             | always multiple ways to create legal loopholes.
             | 
             | If we consider the Irish sandwich mechanism that was
             | recently "stopped", somehow that hasn't materially affected
             | any of the innumerable companies that were using it. As we
             | saw in the Apple vs EU case, most practices might've never
             | been actually legal either.
             | 
             | So my personal opinion is that (almost) all tax
             | "optimization" is at the minimum immoral, but most likely
             | illegal too.
             | 
             | Edit: This reminds me of the idea of temporarily
             | embarrassed millionaires. Your personal optimization is not
             | what I'm talking about - corporations have legal teams the
             | size of SMBs lobbying/creating/looking for secret
             | loopholes, and people are talking about public self service
             | methods.
        
               | marcinzm wrote:
               | If a government says do X and I will cut your takes by Y
               | then is doing X immoral?
        
               | yunohn wrote:
               | If a government "says"? These large companies actively
               | campaign, draft, and lobby for the legal frameworks and
               | loopholes that they exploit. The government and the
               | companies are the same and are fighting for the same pot
               | of tax money.
        
               | DrillShopper wrote:
               | It depends on what X is.
               | 
               | If X is "install solar panels" or "provide affordable
               | housing" or "reduce greenhouse gas emissions" then X is
               | very likely moral.
               | 
               | If X is "lie to us about where your revenue came from"
               | then X is very much immoral.
        
               | bryanrasmussen wrote:
               | no government says "lie to us about where your revenue
               | came from and we will cut your taxes"
        
               | przemub wrote:
               | @bryanrasmussen I wouldn't put it past the Irish one!
        
               | sokoloff wrote:
               | I'm sorry for my immoral behavior of generally holding
               | investments for more than a year, contributing to my
               | 401(k) and HSA accounts, buying an EV, and installing
               | energy efficiency upgrades in my house, all of which are
               | driven by tax optimization (at least in part).
        
         | salawat wrote:
         | It isn't really _accepted_ anywhere, but there is a group of
         | people who will make it their goal in life to get up to any
         | shady practice to try to shortchange or dodge their local host
         | polity to their ultimate advantage. The tax dodge, if you will,
         | becomes something of a pass time and point of pride for them.
         | 
         | This becomes more difficult as more tax authorities better
         | integrate with one another, which admittedly, is something many
         | in in the U.S. fidget over, even if it is realized that the
         | need for it is almost entirely a byproduct of these types of
         | people's actions that necessitate that happening.
        
         | marcinzm wrote:
         | Given Wirecard I wouldn't assume the EU equally prosecutes or
         | tracks crimes for EU and non-EU companies.
        
           | DanielHB wrote:
           | They obviously target the companies the highest revenues.
           | Also you would be suprised. For example Klarna, a Swedish
           | company, is often in trouble with the Swedish tax
           | authorities.
           | 
           | A few years ago they had to pay huge amounts of money to the
           | Swedish government because of some tax-dodging loophole was
           | deemed illegal by court-order. So Klarna went into a
           | desperate attempt to last-minute cut costs to not tank the
           | stock value due to much lower expected returns that quarter.
           | 
           | It was kinda funny because the employees of Klarna are
           | unionized they couldn't just fire anyone on short notice like
           | that, but they did let go pretty much all consultants in one
           | swoop. If this was the US the CEO would have just fired a
           | bunch of people because the CFO f-ed up. For a few months
           | there was a major glut of former-Klarna consultants around in
           | Stockholm, two of them ended up at my company at the time.
           | 
           | I couldn't find details about this tax dodging online (it was
           | around 5 years ago), but here is another article about Klarna
           | being in trouble over GDPR violations:
           | 
           | https://www.reuters.com/technology/swedens-klarna-
           | fined-7330...
        
           | Hamuko wrote:
           | Isn't the Wirecard case still pending with execs in jail
           | waiting for trial?
        
             | marcinzm wrote:
             | Only after it all imploded did the government go after
             | them.
             | 
             | Until that moment it did the exact opposite including
             | opening criminal investigations into the journalists
             | calling it a scam.
        
             | lifestyleguru wrote:
             | The protagonist was first the apple of Merkel's eye and
             | then vanished in Russia.
        
         | lm28469 wrote:
         | > Wasn't Uber or some other US company found doing something
         | similar?
         | 
         | Airbnb, they had to pay like 70k of tax a few years ago. There
         | are employees who pay as much tax as single filers lol
         | 
         | They paid 18% less tax in 2016 than in 2013 while the number of
         | flats available on the site went from 30k to 300k
         | 
         | https://www.lesechos.fr/2016/08/airbnb-na-paye-que-69168-eur...
        
           | scotty79 wrote:
           | All spending should be taxed instead of income. Income is too
           | easy to move and hide. Spending tax could be unified
           | framework encompassing all financial activity. If you
           | purchase anything, labor, imports, energy, stock,
           | politicians, you should be taxed.
           | 
           | Spending is the moment when the money shows its ugly head and
           | does harm.
        
             | thrw42A8N wrote:
             | Revenue tax? We had that before the fall of the wall - not
             | again please. The VAT system works well and should be used
             | more.
        
               | scotty79 wrote:
               | Purchase tax would work like reverse VAT. Companies could
               | be awarded tax credits for their sales (not 100% though)
               | and pay tax on their purchases. This would be harder to
               | evade and additionally incentivise companies to do more
               | with less which might be good for environmental
               | transition.
        
               | thrw42A8N wrote:
               | Why not 100%? How is that even supposed to work in low-
               | margin markets like construction, where the profit is
               | 100x less than the costs, so even 1% tax would erase it?
               | But any markets really, this makes innovation and
               | business so risky that I'd probably close down my IT
               | company too.
        
               | scotty79 wrote:
               | The strength of markets is that they adjust to
               | environment. Taxation is a part of the environment.
               | Taxation would be just priced in.
               | 
               | Why would it be risky to pay some percentage more on what
               | you spend but not pay income tax at all?
        
               | thrw42A8N wrote:
               | Markets will adjust, sure. It will be priced in, but
               | that's the problem. They will become less efficient,
               | quality will be worse, everything will be slower, more
               | risk averse, and thus more expensive to the customer -
               | that is necessary to survive in this new environment.
               | That also means that people's income gets lower and grows
               | slower.
               | 
               | It'd be risky because I have no idea if I'm actually
               | going to make money or not. European states set very
               | draconian rules like 1% daily interest on unpaid taxes -
               | no way I'm taking this shit on.
               | 
               | Just do the same thing but with VAT...
        
               | scotty79 wrote:
               | Two factors are responsible for the bulk ens*ttification
               | of the markets: any barriers to competition and
               | information asymmetry between purchaser and seller.
               | Taxation is not a factor unless it's done with too much
               | micromanagement that incentivises doing weird things to
               | your product/service to avoid higher tax.
               | 
               | VAT is already a purchase tax, just collected from the
               | end consumer. You could just raise VAT and do away with
               | income tax. But since the burden is on the end consumer
               | only (not along the chain, because of 100% deductions) it
               | would have to be raised very high. And VAT is with us
               | long enough that many ways to exploit its edge cases were
               | discovered. General purchase tax collected at all steps
               | of production chain could spread the tax burden away from
               | final consumer to the people who exploit them (aka
               | businessmen) thus fulfilling the role that income tax
               | currently fulfills. It would also have way less edge
               | cases and could replace things like import tariffs and
               | social security fees, excise taxes and many more.
               | 
               | > It'd be risky because I have no idea if I'm actually
               | going to make money or not.
               | 
               | That's the inherent risk of business. You have to decide
               | if it's worth it regardless of whether a server costs you
               | $x or $x+10% purchase tax.
               | 
               | > European states set very draconian rules like 1% daily
               | interest on unpaid taxes - no way I'm taking this shit
               | on.
               | 
               | You would never have unpaid taxes because they'd be
               | automatically collected by the bank at the moment of
               | purchase. If you don't have money to pay for purchase tax
               | you don't have money to make a purchase.
               | 
               | > Just do the same thing but with VAT...
               | 
               | We could do some of that if we reduced VAT deductions
               | from 100%. But it would be worse because VAT is very
               | limited and thus has a lot of edge cases where it comes
               | in contact in systems outside it's domain. Those can be
               | used to get away from paying by doing superfluous
               | operations.
        
               | immibis wrote:
               | ... prices would increase to cover the tax?
        
               | Aunche wrote:
               | ...or you can just use a VAT, which are also paid at
               | purchase. Tech companies have high margins and low
               | expenses, so if the point is to tax tech companies,
               | taxing purchases and giving a credit to sales is
               | literally the exact opposite of what you want to do.
        
               | scotty79 wrote:
               | VAT with 100% deduction places entire tax burden on the
               | end consumer. Income tax aims to extract additional tax
               | from entities that extract money from consumers for
               | investors.
               | 
               | VAT could do a lot of the same things that I'm proposing
               | (if the deductions weren't 100%) but is limited in scope.
               | And because of that it has a lot of interfaces to other
               | domains like real estate, import, labor, financial
               | intruments. Interfaces that can be exploited to avoid
               | paying taxes.
               | 
               | General purchase tax could replace all taxes and fees
               | transfered from the markets to governments (and
               | effectively goverment managed buckets like social
               | security or public healthcare).
               | 
               | Taxes have this strong moral objection that they are
               | punishment for creating value. Purchase tax could help
               | with that by ostensibly being punishment for using up
               | value not for creating value. It might also compose well
               | with transition to stable state economy that will have to
               | replace old economy based on unbounded growth.
        
             | lotsofpulp wrote:
             | Correct, and it could be implemented as a power law formula
             | that makes it impossible for the super rich to avoid tax
             | (since they are the only ones that can spend a lot). It
             | also aligns incentives with environmentalism and reducing
             | waste and consumption. And poorer people are automatically
             | exempted from tax since the power law formula parameters be
             | set to slowly ramp up.
             | 
             | This is also easily accomplished now that almost all
             | payments are happening digitally, assigned to a taxpayer
             | ID#. We can easily replace a W-2 or 1099 with total
             | spending instead of taxing working.
             | 
             | Of course, this should also be paired with similarly
             | designed land value and estate taxes to disincentivize
             | hoarding.
        
               | shermantanktop wrote:
               | So my effective tax rate on consumption is indexed on my
               | ability to hide my assets?
               | 
               | Maybe my household LLC should buy all my groceries while
               | I work for the LLC which employs me as the sole
               | contractor and live in the house that I rent from the LLC
               | which I am the sole owner of. For major purchases, I can
               | hire a low-income person to do the purchase and then sell
               | the item to me, or maybe they lease it to me.
               | 
               | I'm not a tax lawyer but it's pretty easy to see the many
               | loopholes in alternative tax proposals.
        
               | lotsofpulp wrote:
               | >So my effective tax rate on consumption is indexed on my
               | ability to hide my assets?
               | 
               | Where are you getting this from? Sales tax has nothing to
               | do with one's assets. Also, land value taxes make hiding
               | assets moot, since all real assets have to be stored on
               | land. Of course, copyright protections would need to be
               | reformed to be for far shorter durations of time.
               | 
               | >Maybe my household LLC should buy all my groceries while
               | I work for the LLC which employs me as the sole
               | contractor and live in the house that I rent from the LLC
               | which I am the sole owner of.
               | 
               | Why should LLC's be exempt from the tax?
               | 
               | >For major purchases, I can hire a low-income person to
               | do the purchase and then sell the item to me,
               | 
               | How does this help? You are still purchasing the item. If
               | you are referring to purchasing it with cash and
               | committing tax evasion, the same is possible with income
               | tax today.
               | 
               | >or maybe they lease it to me.
               | 
               | Renting something is still considered a sale. You get
               | charged sales tax at hotels. Renting apartments is not
               | usually subject to sales tax, but that is a policy
               | choice.
        
               | vlovich123 wrote:
               | > Where are you getting this from? Sales tax has nothing
               | to do with one's assets
               | 
               | Earlier you said
               | 
               | > And poorer people are automatically exempted from tax
               | since the power law formula parameters be set to slowly
               | ramp up
               | 
               | I too am very confused on how you envision this sales tax
               | working where it's variable in some way that poor people
               | don't get the tax but rich people do so I understand why
               | OP is asking about asset tracking. If you're talking
               | about it as a tax that increases the more you spend
               | you've still got problems of hiding how much I'm spending
               | through various legal entities. It also has a macro
               | economic problem, at least how the consumer economy is
               | structured, that could slow down the gears of business
               | until society realigns (if it does) because people will
               | be incentivized to consume less. You've got alternative
               | models where you go after specific products and tax more
               | for conspicuous consumption like yachts but that feels
               | like it has all the inefficiencies of central planning a
               | market.
        
               | lotsofpulp wrote:
               | >that poor people don't get the tax but rich people do
               | 
               | Because poor people can't spend money (since they don't
               | have it), hence they pay much less (or even no tax). The
               | curve of a power law formula can be modified to whatever
               | is socially acceptable. Otherwise, rich people who are
               | hoarding assets will get taxed via land value taxes
               | utilizing the same framework.
               | 
               | >you've still got problems of hiding how much I'm
               | spending through various legal entities.
               | 
               | Same with income tax. Completely stamping out tax evasion
               | is not a realistic goal with any system. Also, various
               | legal entities are all tied to beneficial owners with
               | taxpayer ID numbers. Databases would make quick work of
               | sorting this kind of stuff out.
               | 
               | >It also has a macro economic problem, at least how the
               | consumer economy is structured, that could slow down the
               | gears of business until society realigns (if it does)
               | because people will be incentivized to consume less.
               | 
               | Yes, that is why it is a pipe dream. But it would
               | actually accomplish environmental goals as opposed to
               | just pay lip service and pretend.
               | 
               | >You've got alternative models where you go after
               | specific products and tax more for conspicuous
               | consumption like yachts but that feels like it has all
               | the inefficiencies of central planning a market.
               | 
               | Completely unnecessary to complicate things which also
               | opens up avenues for corruption. A yacht is super
               | expensive, it's obviously going to be hit with a ton of
               | tax. Just come up with a tax curve (like we already do
               | with the various income tax deductions/brackets) that
               | provides the tax revenue and still allows people to spend
               | enough money to provide for their basic needs.
        
               | vlovich123 wrote:
               | > Because poor people can't spend money (since they don't
               | have it), hence they pay much less (or even no tax)
               | 
               | Poor people can buy a car. Middle class families can buy
               | 2 cars. Neither can buy 100 exotic cars. Is the purchase
               | of each additional car going to increase the tax paid?
               | Are exotic cars taxed more? You keep stating to use a
               | power law formula but you're critically omitting what the
               | inputs are to determine your tax rate. And now you've
               | also admitted that assets determine your sales tax
               | whereas you seemed to be arguing earlier that that wasn't
               | the case when asked if the sales tax rate is dependent on
               | your ability to hide assets.
               | 
               | > Otherwise, rich people who are hoarding assets will get
               | taxed via land value taxes utilizing the same framework
               | 
               | Rich people hoard assets in all sorts of ways including
               | collecting physical items which you can store where land
               | is cheap if you wanted. That's why the income tax is
               | effective - it's taxation at the moment the money changes
               | hands / you've realized a gain.
        
               | lotsofpulp wrote:
               | > Is the purchase of each additional car going to
               | increase the tax paid?
               | 
               | Yes, tax liability = total spending during the year
               | plugged into the power law tax formula.
               | 
               | >Are exotic cars taxed more?
               | 
               | Depends how much the taxpayer spends in a year. There is
               | no tax rate for each specific item. The tax rate is for a
               | total level of spending, which eliminates all loopholes.
               | 
               | > You keep stating to use a power law formula but you're
               | critically omitting what the inputs are to determine your
               | tax rate.
               | 
               | The input is total spend in a year. Just like right now,
               | the input is income in a year.
               | 
               | > And now you've also admitted that assets determine your
               | sales tax
               | 
               | No, I did not. The formula to calculate sales tax
               | liability only requires inputting total spending. Land
               | value taxes are a separate thing. We currently have land
               | value taxes, except they are flat rate and too low
               | because property taxes inefficiently tax improvements on
               | the land more than the land itself.
               | 
               | > That's why the income tax is effective - it's taxation
               | at the moment the money changes hands / you've realized a
               | gain.
               | 
               | Sales tax can also be at the moment the money changes
               | hands. It currently is. Even with the complication of a
               | power law tax formula, I can't see why the government
               | can't email you a monthly invoice.
        
               | scotty79 wrote:
               | Do you have any keywords for me that I could read up on?
               | 
               | I came up with the idea of puchase tax and progressive
               | real estate tax myself, but I'm sure other people had
               | same ideas before me.
        
             | vlovich123 wrote:
             | Isn't that a hugely regressive tax?
        
               | scotty79 wrote:
               | I don't think so. Rich people buy vastly more. Not just
               | food, shelter and entertainment but also real estate,
               | entire companies and financial instruments. They'd end up
               | paying vastly more tax.
        
               | betaby wrote:
               | > Rich people buy vastly more
               | 
               | Not enough, especially since everything is business
               | expense for them.
        
               | marcosdumay wrote:
               | If you add financial instruments into the tax (what is a
               | tax on investing, not spending), it will become
               | proportional. What is still not very good.
               | 
               | This blind kind of tax also has horrible impact on the
               | production of goods with high added value.
        
           | thrw42A8N wrote:
           | > They paid 18% less tax in 2016 than in 2013 while the
           | number of flats available on the site went from 30k to 300k
           | 
           | Completely meaningless without also saying what their costs
           | and investments were.
        
             | lm28469 wrote:
             | Well no that's not really what happens, what happens is
             | that legally the french entity is just a service provider
             | for the irish HQ. They pretend it's a simple marketing
             | agency and that the real value is provided by the irish
             | entity
        
               | thrw42A8N wrote:
               | Doesn't matter - you can't make any judgement without
               | knowing these numbers. They may have actually paid a
               | higher tax rate than previously - we don't know.
        
               | lm28469 wrote:
               | Funny how it works, they lose money everywhere but one of
               | the smallest country they operate in banks 50% of their
               | worldwide revenues, it probably is just a coincidence
               | that this is a tax heaven... we just don't know I guess
               | 
               | The French branch made 160k of profit while the Irish
               | branch made more than all the other EU countries combined
               | 
               | FYI: france is the second market for airbnb after the
               | US... do you really think they would even bother if they
               | did make 160k there when they make 300m+ per year
               | globally ? Do you really think their second market nets
               | them < 0.1% of their total net income ? Do you really
               | think the most touristic country in the world in absolute
               | numbers brings 160k euros per year to airbnb ?
               | 
               | I dont't know much but I'm not a fool
               | 
               | https://en.wikipedia.org/wiki/World_Tourism_rankings
               | 
               | https://www.searchlogistics.com/learn/statistics/airbnb-
               | stat...
               | 
               | https://www.rte.ie/news/business/2023/1127/1418779-revenu
               | es-...
               | 
               | https://www.breakingnews.ie/business/airbnb-ireland-
               | records-...
        
               | thrw42A8N wrote:
               | I don't know why you're telling me this, I know it - and
               | it's not relevant at all without knowing the numbers.
        
               | ClassyJacket wrote:
               | I guess it's just a crazy coincidence that most huge
               | multinational corporations base their European operations
               | in Ireland then? They just like drinking Guinness I
               | suppose?
        
               | lm28469 wrote:
               | Well you said it doesn't matter because we don't know the
               | numbers, yet the numbers we do know about don't match any
               | scenario that doesn't involve large scale tax
               | """optimisation"""
        
               | Muromec wrote:
               | At some point governments will catch up and start taxing
               | based on percentage of global revenue or even turnover.
        
               | betaby wrote:
               | I hope so. And that's not only USA-copanies phenomenon. I
               | worked for a french company in Montreal which payed close
               | to zero tax amount even though they are doing more than
               | OK financially world-wide, including Canada.
        
         | seanhunter wrote:
         | Yeah there's the so called "Dutch Sandwich"[1] which is a well-
         | known tax "planning" methodology that corporates use with the
         | so called "Double Irish" being another one. There's also a
         | slightly less-well known one involving Mauritius and India.
         | They're all ways of moving profits between companies in order
         | to exploit tax treaties that countries put in place. In the
         | case of the Dutch sandwich I think the Netherlands has a treaty
         | with the Netherlands Antilles or something so people have a
         | company in the Netherlands which then shifts things off-shore
         | to the Antilles and avoids tax that way.
         | 
         | It's nonsense of course. Companies should (in my opinion)
         | shoulder their fair share of tax because otherwise that burden
         | falls disproportionately on individual income tax.
         | 
         | [1] https://en.wikipedia.org/wiki/Dutch_Sandwich
        
           | s_dev wrote:
           | Your information is outdated -- Double Irish is no longer
           | applicable according to your own source since 2010.
        
             | yunohn wrote:
             | No, it's much more complicated than that. If you scroll a
             | bit further:
             | 
             | > After pressure from the EU,[22] the Double Irish BEPS
             | tool was closed to new users in 2015,[citation needed]
             | however, new Irish BEPS tools were created to replace
             | it:[23][24]
             | 
             | Not only do the original evaders get to continue doing it,
             | they've also found new loopholes already.
        
               | Muromec wrote:
               | It's like eruv. The loophole was planted there for us
               | mortals to find and use it
        
               | seanhunter wrote:
               | Right. Also I wasn't trying (nor am I equipped) to give
               | some kind of current guide to tax dodging. I was
               | explaining the basic sort of thing people do. The
               | specifics change all the time because there is a sort of
               | whack-a-mole that tax authorities try to play to get
               | people to pay and people pay ever more and more inflated
               | fees to various accountants and tax "planning" experts
               | for ever more byzantine and artificial schemes of one
               | kind or another.
               | 
               | My own experience with tax experts has left me pretty
               | jaded about tax advice. It seems to me that often these
               | companies have maybe 1 dude who actually understands tax
               | and an army of people with powerpoint going out selling
               | the "solution". I had a complex tax situation when
               | setting up a business in the UK and US and got tax advice
               | from one of the big four firms not to dodge tax but to
               | make sure I understood the US system correctly and was
               | paying everything I should. I paid _so much_ tax that I
               | got investigated in both the UK and US because they
               | thought there must be some sort of fiddle because I
               | seemed to be paying way more than I sholud be (this was
               | what I told the accountants). I ended up getting rebates
               | from the IRS and from the UK HMRC after the
               | investigations but it took a couple of years to get it
               | all sorted out.
        
           | tiahura wrote:
           | What's the rationale for double taxing corporate profits vs
           | other types?
        
             | seanhunter wrote:
             | No rationale for that, but likewise no rational reason that
             | corporates sholud be able to use multinational structures
             | to completely avoid tax, which is what these planning
             | structures are all about. Typically there are inter-company
             | transfer pricing arrangements that mean that the companies
             | in the taxed jurisdictions pay fees to each other so their
             | profits are minimised and as much profit as possible is
             | expatriated to low- or no-tax jurisdictions.
        
           | gamblor956 wrote:
           | None of these tax "planning" schemes are available anymore.
           | 
           | Moreover, tax authorities have increasingly taken the
           | position that the use of these planning methods constitutes
           | tax evasion. The Dutch Sandwich and Double Irish were
           | grandfathered in (meaning, not treated as criminal tax
           | evasion) but a company utilizing similar schemes today would
           | ultimately result in one or more of their executives spending
           | time in jail.
           | 
           | Critically, most of tax law is actually _regulation_ that
           | implements statutes. Tax planning schemes that satisfy the
           | technical letter of regulations but which violate the plain
           | intent of the written statute can, and have, been deemed
           | illegal years or even decades later (see, for example, the
           | Bermudan tax loss harvesting scheme), and this has repeatedly
           | passed constitutional muster.
        
         | scotty79 wrote:
         | That's rich coming from French. Long time ago France Telecom
         | bought Polish top phone network. Immediately rebranded it to
         | Orange (despite the fact that the company had one of the
         | strongest brands on market where it operated).
         | 
         | Unsurprisingly the licensing fees for using Orange brand that
         | the Polish company had to pay to France Telecom amounted to
         | large percentage of taxable profits that the Polish company
         | had. Overt theft from Polish company and Polish taxpayers.
        
           | mort96 wrote:
           | Nation state acts in its own interest, news at 11
           | 
           | No but seriously, this doesn't sound surprising? Why should
           | France be against a French company buying up other companies
           | and bringing revenue back to France
        
             | scotty79 wrote:
             | Do you want euroscepticism? Because that's how you get
             | euroscepticism.
        
               | mort96 wrote:
               | I don't understand the problem honestly. I'd understand
               | it if Poland stepped in and didn't let the company be
               | bought out, but this just seems like bog standard normal
               | globalized free market stuff? It would be extremely weird
               | for _France_ to step in and prevent a French company from
               | buying a Polish company due to fears of stoking
               | Euroscepticism among the polish population wouldn 't it?
               | And I don't even know what this has to do with the EU,
               | companies have been buying up companies from other
               | countries both in and out of the EU forever?
        
               | scotty79 wrote:
               | I also don't expect nothing other from thief then
               | continuing to steal.
               | 
               | I also expect thieves to be protective of their own
               | assets.
               | 
               | I'm just saying they are still thieves and any outrage in
               | their name is misplaced.
               | 
               | Screw the French when they are robbed for the benefit of
               | other countries, because they steal from other countries
               | using their public companies as well.
        
           | lifestyleguru wrote:
           | Ohhh the memory of their atrocious and extortive services
           | still raises my adrenaline. The French bought the position of
           | monopolist in the telecom market. That's (and similar
           | privatization frauds) how the only true Russian-style
           | oligarch in Poland was created - Jan Kulczyk. Thanks, French!
        
           | greyw wrote:
           | Is that related to the privatization wave after 1989? If so,
           | the culprit here is the corrupt political caste that sold
           | companies below their true value for kickbacks. Corruption
           | has been an endemic problem in the east.
        
         | _ink_ wrote:
         | Is it illegal, tho?
        
       | seiferteric wrote:
       | I wonder how these "office raids" would work for remote first
       | companies that don't have much of an office presence and with
       | little or no physical documents and everything being stored in
       | the cloud somewhere.
        
         | nerdponx wrote:
         | If you can get access to someone's laptop with SSO login access
         | to the cloud storage (or their email inbox and Slack messages),
         | then you have what you need.
        
           | aspenmayer wrote:
           | IIUC email messages on cloud services older than 180 days
           | don't even require a US warrant(!) anyway.
           | 
           | https://www.eff.org/deeplinks/2013/05/update-email-
           | privacy-l...
           | 
           | https://en.wikipedia.org/wiki/Electronic_Communications_Priv.
           | ..
        
         | Etheryte wrote:
         | I mean, that would be way easier for the government agencies,
         | no? Just send a subpoena to the service providers, they hand
         | over all the data and you're done?
        
         | crest wrote:
         | If everything is synchronised to third party could storage an
         | "office raid" can be as easy as getting a court order telling
         | the cloud provider to make a snapshot of everything stored
         | available to the police.
        
           | spwa4 wrote:
           | Is there a product allowing for client-side encrypted mounts?
           | Or just use a SAAS outside of the country that doesn't allow
           | for exporting any data under any circumstances?
        
             | playingalong wrote:
             | The whole point (or at least the main point) of the tax
             | paperwork is to be able to produce them to tax
             | investigators. If you don't want to share anything, then
             | it's easier not to do the accounting. Which I guess is
             | severally illegal globally.
        
               | HelloNurse wrote:
               | Being unable/unwilling to produce mandatory records is
               | fraud. Technical measures to be unable to produce records
               | (e.g. offshore and encrypted archival) are evidence of
               | criminal intent and possibly separate crimes.
        
               | spwa4 wrote:
               | So why did every company in the world start auto-deleting
               | emails ~10 years ago? I don't believe many people were
               | sued for fraud. These days cloud services have auto-
               | delete based on time functionality?
               | 
               | It's called "object lifecycle management", because I
               | guess fraud was too catchy.
        
               | gruez wrote:
               | Usually tax laws have a cut-off date. You don't need to
               | keep records forever, but you do need to keep them around
               | for a few years.
        
               | spwa4 wrote:
               | Strange, because that sounds reasonable but the reasoning
               | doesn't actually work, does it?
               | 
               | Either "the law" can be trusted, and there's no point to
               | deleting data after a cut-off date, or the reverse is
               | true and you're no worse off getting caught deleting
               | data.
               | 
               | I believe the law actually provides a middle ground.
               | You're liable for tax fraud for X years, but you're
               | allowed to delete the data after Y years. Since X > Y you
               | make it much harder for the tax office to sue you if you
               | delete data. Plus make it pointless for them to use their
               | other investigative powers against you, which is in
               | reality more important, especially for smaller firms.
        
               | izacus wrote:
               | You mean the auto-deletion that DOJ considered as
               | deliberate destruction of evidence in Google case? [0]
               | 
               | Or are you talking about deliberate destruction of
               | accounting records, which are required to be held by the
               | relevant law of the governments?
               | 
               | [0]:https://www.legaldive.com/news/doj-google-spoliation-
               | hangout...
        
             | Muromec wrote:
             | It's not the game you can win against the government
        
         | s_dev wrote:
         | I'd imagine you'd get done for not being tax compliant. At
         | least in Ireland you have to able to show all tax accounting
         | for the last four years on request by Revenue. If you can't
         | produce this and all the files 'have gone missing' or 'we can't
         | find the cloud keys' I'd would expect to be fined out of
         | existence and ordered to cease trading immediately. So that
         | would be worse that getting dragged through the courts while
         | you pay lawyers to figure out to mitigate any fines or
         | sentences passed down. I think it can even result in prison
         | time for the CEO and other company officers.
        
           | dylan604 wrote:
           | I'd expect it to something along the lines of "sorry Mario,
           | but the princess is in a different castle" bit of shell game.
           | "no no mister Revenue man, we have that information you want,
           | but it's in a different office".
        
             | s_dev wrote:
             | There is only so much you can play whack a mole --
             | virtually nobody 'cheats' the taxman. There are plenty of
             | legal loopholes etc. if you are smart enough to use them.
             | 
             | If you aren't -- you'll find the enforcement end of the tax
             | authorities in ANY country are pretty efficient. Even in
             | third world countries where many services are falling down
             | the tax authorities will be a well oiled machine as the
             | stability of the entire country rests on the government
             | even corrupt ones to collect taxes.
        
             | avianlyric wrote:
             | This is why companies are required to have registered
             | addresses. As far as the law is considered, that address is
             | where all your records can be accessed, and requested from.
             | 
             | If the state turns up at that address, and you tell them
             | they're at the wrong address, then the directors start
             | becoming liable for fraudulent behaviour.
        
           | beeboobaa3 wrote:
           | sure but politely demanding some documents is not the same as
           | raiding an office
        
           | eastbound wrote:
           | Accounting audits are done by the FISC agency in France. But
           | those are just audits, not raids. This raid was ordered by a
           | judge, which can probably be seized by FISC if they believe
           | that the documents they have are falsified.
        
         | diggan wrote:
         | > everything being stored in the cloud somewhere
         | 
         | Sounds like it would make it easier for law enforcement. They
         | no longer need a warrant against/for the company they're
         | investigating, just the place where their data is stored. Get
         | the warrant, raid the place and grab the drives, then continue
         | the investigation. Done the right way, the company under
         | investigation wouldn't even notice it.
        
           | seiferteric wrote:
           | That's why I wonder if these raids are really more for show,
           | can't they do this pretty much already?
        
             | belter wrote:
             | Completely for show since they even make press releases
             | about it.
             | 
             | And its sad to see the atrocious quality of the BBC
             | article. Even high school students learn that a
             | journalistic piece, should make sure it touches the Five Ws
             | of good journalism...
             | 
             | https://en.wikipedia.org/wiki/Five_Ws
             | 
             | The Hollywood Reporter has much better quality reporting
             | including context:
             | https://www.hollywoodreporter.com/business/business-
             | news/net...
        
           | oceanplexian wrote:
           | The data is stored on a server in another country where the
           | warrant isn't worth the paper it's printed on. Now what?
        
             | crossroadsguy wrote:
             | That is why countries are increasingly demanding (and
             | mandating) those data (of citizens and business done there
             | or that involves that nation or its citizens) to be stored
             | inside their borders.
        
           | scarface_74 wrote:
           | First the data is stored in another country. Second are they
           | really going to raid and take the drives at an AWS data
           | center that has other customer's information? How will they
           | know which drive to take?
        
             | gruez wrote:
             | >First the data is stored in another country.
             | 
             | Plus you can engage in some jurisdiction arbitrage where
             | all the documents pertaining to country A is stored in
             | country B, and all the documents pertaining to country B is
             | stored in country A.
             | 
             | > Second are they really going to raid and take the drives
             | at an AWS data center that has other customer's
             | information?
             | 
             | You can also ask AWS to produce the files/documents for
             | you.
        
               | scarface_74 wrote:
               | And those files are hopefully encrypted at rest and
               | probably using a customer managed key...
        
               | gruez wrote:
               | >using a customer managed key...
               | 
               | Not an AWS expert but how does that even work? Does AWS
               | connect to your HSM remotely? Or is a cloud HSM that's
               | also hosted by AWS?
        
               | scarface_74 wrote:
               | (Source: I am a current high level employee at a third
               | party AWS consulting company and former employee at AWS
               | working in the Professional Services department)
               | 
               | I actually was imprecise with my wording.
               | 
               | A customer managed KMS key is any key that you make
               | instead of using an AWS provided key. AWS still has the
               | means to theoretically decrypt the data.
               | 
               | I am actually referring to a customer managed KMS key
               | where you import your own key material
               | 
               | https://docs.aws.amazon.com/kms/latest/developerguide/imp
               | ort...
               | 
               | There is also CloudHSM
               | 
               | https://aws.amazon.com/cloudhsm/faqs/#:~:text=AWS%20Cloud
               | HSM....
               | 
               | I don't know how far "AWS doesn't have access to your
               | keys go" when it comes to a government subpoena.
               | 
               | I do know that if anyone accesses anything on your
               | account from AWS, all sorts of internal alarm bells go
               | off at AWS and it would still show up in your CloudTrail
               | logs.
               | 
               | I'm sure there is _something_ that allows internal AWS
               | employees to access your account in unauthorized ways.
               | But I never heard about it in 3.5 years working there in
               | the Professional Services department.
        
           | SirMaster wrote:
           | Grab the drives from the cloud?
           | 
           | Isn't most data in the cloud heavily distributed and broken
           | into shards across many racks and drives and such? And
           | encrypted so is useless outside of the custom block storage
           | system employed by the cloud provider?
           | 
           | They would need to decrypt and assemble the shards to get
           | usable data out.
           | 
           | I have no clue how they would even know which drives out the
           | tens of thousands to grab, and they would also have other
           | customer's data on them.
        
             | Hikikomori wrote:
             | It's simple, just grab all of S3.
        
             | kube-system wrote:
             | They'll just get a warrant to search the live system as it
             | is powered on rather than take a cold drive.
             | 
             | https://leb.fbi.gov/articles/featured-articles/executing-
             | sea...
             | 
             | Or in China, just take the entire data center. https://www.
             | theregister.com/2018/01/11/icloud_china_goes_to_...
        
         | rty32 wrote:
         | I don't know how it works in other countries, but in the US you
         | likely still need to provide a real address for many purposes
         | (tax, immigration if applicable, etc)
         | 
         | The police could just find the correct targets and raid their
         | home instead.
        
           | EVa5I7bHFq9mnYK wrote:
           | I have a virtualmailbox.com address - all my banks, the IRS,
           | state voting commission and USCIS (immigration authorities)
           | are all perfectly fine with it.
        
             | aspenmayer wrote:
             | Wouldn't your identity documents required to open a bank
             | account show a residential address?
        
               | EVa5I7bHFq9mnYK wrote:
               | Can't say for sure. I opened all my bank accounts while
               | still having a proper residential address, but after
               | relocating to another country changed the address to a
               | virtual one, no one said a word.
        
         | isodev wrote:
         | It depends on the type of business. In the EU, VAT registered
         | companies are usually mandated to have a physical location and
         | local representative within the country of operation. So you
         | can be remote all you want, as long as your company and fiscal
         | representative can be reached at a physical location.
        
           | ExoticPearTree wrote:
           | Yes, but you can hire anyone as an administrator and promise
           | them a whole of money if they end up having issues with the
           | law.
           | 
           | I would hire homeless people to "run" the company.
        
             | betaby wrote:
             | In Canada hire indigenous people as owner to save on taxes
             | / get preferential treatment. See ArriveCAN (non-)scandal.
        
             | isodev wrote:
             | A homeless person wouldn't qualify as they don't have a
             | fixed address which is mandatory.
             | 
             | Ultimately, if you really have bad intentions, you find a
             | way. It's a question of risk and responsibility if you want
             | to put yourself in such a position or not.
        
         | _ink_ wrote:
         | There was an interview with Anne Brorhilker, who used to be
         | state's attorney and was investigating in CumEx cases. She
         | stated that it is a huge pain, because you always need to ask
         | the foreign agencies for assistance, which you sometimes simply
         | won't get.
         | 
         | It was a good listen. At first she needed to go empty handed,
         | but then teamed up with competent tech guys. After that the
         | smug faces stating, that the amount of data would be to much to
         | handle for her little department quickly turned into concerned
         | faces.
        
           | tenacious_tuna wrote:
           | That sounds fascinating, do you happen to have a link? (I'm
           | getting a lot of German results, which unfortunately I don't
           | have the fluency to parse to find the 'right' one.)
        
             | _ink_ wrote:
             | Here you go: https://logbuch-
             | netzpolitik.de/lnp500-zombiecalypse-im-grune... (it's in
             | German, tho)
        
               | tenacious_tuna wrote:
               | that's fine! I can handle translating an individual page
               | (or interview) if I've high confidence it's the
               | right/relevant one, just parsing search results is harder
               | cross-language (for me, anyway).
               | 
               | thanks much!
        
               | chmod775 wrote:
               | Here's a direct link to the transcript if you haven't
               | found it yet: https://logbuch-
               | netzpolitik.de/lnp500-zombiecalypse-im-grune...
        
               | _ink_ wrote:
               | Nice!
               | 
               | > Tim Pritlove: Okay, zweiter Bildungsweg. Welches
               | Instrument haben Sie denn gespielt?
               | 
               | > Anne Brohrhilker: Klavierung, Pferdflote.
               | 
               | Oh, AI transcribed. Nevermind.
        
           | junto wrote:
           | Holy crap that's an interesting interview. Genuinely
           | hilarious comment from that CIO as well. I knew nothing about
           | this case before. Thanks for sharing.
        
         | asveikau wrote:
         | What do you think "the cloud" is? I'm reminded of an old meme,
         | "the cloud is just someone else's computer". They could raid a
         | data center and seize machines. They could also subpoena data
         | they are looking for.
        
           | lowkey_ wrote:
           | You'd likely be seizing a bunch of other innocent people's
           | data too, then, no?
           | 
           | As an American, I'd be really surprised if we let that
           | happen. I looked and found it apparently happened once, in
           | 2009 in Texas: https://www.cio.com/article/278564/data-
           | center-when-the-fbi-...
           | 
           | It resulted in another company essentially being shut down,
           | and suing for their data back. Crazy. There has to be a
           | better way of doing that digitally (I assume there is, these
           | days, and we won't see something like this again).
        
             | asveikau wrote:
             | The idea that running stuff in the cloud will protect you
             | from a criminal investigation is totally absurd.
        
           | grecy wrote:
           | What if those machines are on another continent?
        
         | oceanplexian wrote:
         | It doesn't. Especially with multinationals, and doubly so as
         | crypto gains adoption. Hence why the governments of the world
         | are in a panic. Decentralization is a huge threat to
         | bureaucracy since their tools of intimidation and control are
         | less effective.
        
           | immibis wrote:
           | Multinationals yes, crypto not really. The problems with
           | crypto are just an extension of the existing "war on drugs"
           | that has never really succeeded at anything besides
           | justifying why lots of tax money should be spent murdering
           | citizens.
        
         | Algent wrote:
         | That's basically what happened when they tried (twice I think
         | ?) to raid Uber offices in France, their boss pressed a kill
         | switch and everything went down in seconds. It completely
         | blocked the investigation.
         | 
         | Afterward Uber helped Macron campaign who then ordered National
         | Financial Prosecutor's office to "stop bothering them" so I
         | don't think anything new happened since.
         | 
         | Edit: Some sources in below replies for infos on both. Turn out
         | I'm wrong for 2nd part it started earlier than his campaign.
        
           | Muromec wrote:
           | Sounds like obstruction of justice or what not
        
           | nicce wrote:
           | > Afterward Uber helped Macron campaign who then ordered
           | National Financial Prosecutor's office to "stop bothering
           | them" so I don't think anything new happened since.
           | 
           | Isn't that kinda definiton of corruption?
        
             | hulitu wrote:
             | No. Corruption is when the others are doing it. /s
        
             | Algent wrote:
             | I do need to correct myself, look like "friendship" started
             | before his election:
             | https://www.euronews.com/2023/07/18/a-privileged-
             | relationshi...
             | 
             | Pretty crazy to support a business designed to never pay
             | tax. This bring nothing beside "precarious employment".
        
             | grecy wrote:
             | Woah, slow down there citizen.
             | 
             | It's been rebranded to "lobbying" and "campaign
             | contributions". Much cleaner. Better optics.
        
             | lm28469 wrote:
             | Ahahahah you fool, don't be ridiculous, in civilized
             | western countries we call it lobbying
        
           | stuaxo wrote:
           | That sounds so illegal, it's crazy there aren't consequences
           | for that.
           | 
           | EDIT: Article on the kills switch
           | https://www.theguardian.com/news/2022/jul/10/uber-bosses-
           | tol...
        
             | lokar wrote:
             | Nothing uber does is crazy anymore
        
               | NBJack wrote:
               | Not by comparison to Uber at least. 'Historical'
               | documentaries about it are going to be wild. And probably
               | on Netflix.
        
               | lokar wrote:
               | I meant they have redefined the bar for crazy to be so
               | high no one will ever cross it. They are the GOAT for
               | crazy.
        
               | fragmede wrote:
               | If you haven't seen superpumped or read the book and are
               | interested in Uber's story, it's worth a read/watch,
               | though it's dramatized for tv.
        
               | DoctorOW wrote:
               | History is written by the winners sadly enough.
        
             | golemotron wrote:
             | The alternative, giving them a password that gives them
             | read/write access to sensitive systems, would be insane.
             | Subpoena for particular data.
        
               | dh2022 wrote:
               | You can give them read access tokens that expire every
               | couple of hours....
        
               | golemotron wrote:
               | The problem is deeper than that. When a physical space is
               | raided, its scope is obvious. Digital spaces don't have
               | that characteristic. There can always be hidden indexes.
        
               | MichaelZuo wrote:
               | Yeah it's hard to see how any French official would have
               | authority to conduct searches 10 meters beyond French
               | borders, let alone over all of Uber's computers located
               | in dozens of other countries.
        
               | wang_li wrote:
               | Hard to see how a company can imagine it can do business
               | in a country and not follow that country's record keeping
               | laws and be subject to criminal and civil statutes in
               | that country.
        
               | MichaelZuo wrote:
               | How is this relevant to Uber's files and computers
               | located in other jurisdictions?
        
               | jraph wrote:
               | If you do business in France, you are accountable in
               | France. Your problem to provide the asked documents if
               | it's the law to provide them. That you are using
               | computers elsewhere to store stuff should not be any
               | relevant.
               | 
               | You shouldn't really be able to have it both ways, should
               | you?
        
               | MichaelZuo wrote:
               | Uber's files and computers located in French territory
               | are of course accountable to French authorities, but
               | that's simply not the case for those located in other
               | jurisdictions...
               | 
               | Unless there is some international law or treaty
               | mandating that?
        
               | wang_li wrote:
               | It's not a matter of what's located in France. It's a
               | matter of what documentation about your company requires
               | you to keep. Regardless of where the computers you use
               | are physically located if you can't produce the required
               | documents you get to be fined, be shut down, and/or go to
               | prison. No company gets to play the game of "we're doing
               | business in Uzbekistan but our accounting servers are in
               | Sealand so we don't have to file any taxes or provide any
               | other records." Not only is the idea absurd, anyone who
               | thinks that is congenitally stupid or stupid by choice.
        
               | jraph wrote:
               | The ableist part of your comment is not necessary, no
               | need to insult people, the rest of your comment (with
               | which I agree) is solid enough without it ;-)
               | 
               | I believe the parent comment is faithful and honest, it
               | merits a respectful answer. I think it actually focuses
               | on a specific aspect of the question that you missed. It
               | actually made me look up how audits in France work more
               | deeply than what I knew.
        
               | MichaelZuo wrote:
               | Attempted insults only decrease the credibility of the
               | writer... anyways I didn't claim Uber is supplying less
               | than the legally required amount of paperwork?
               | 
               | Nor is it likely.
               | 
               | All the accounting, insurance, banking, regulatory,
               | etc... paperwork legally necessary for even a large
               | company in France can easily fit in a set of binders that
               | fit in a single bookcase.
               | 
               | So it's literally possible for all of it to be ready and
               | available for inspection before anyone even touches a
               | keyboard. And in fact that was the case for every company
               | in France pre 1960s.
        
               | jraph wrote:
               | Authorities might not be able to seize computers and
               | files in another country, although I think interpol can
               | get involved in tax fraud or tax evasion matters.
               | 
               | Preventing access to your accounts during an audit is
               | quite fishy, especially for an onsite audit without
               | warning which, in France, is supposed to happen only if
               | the authorities have doubts that you could make some
               | evidences disappear. During an audit, the CEO is supposed
               | to provide the documents, the inspectors are not supposed
               | to access your files themselves I think.
               | 
               | (So blocking access for security reasons is bullshit, to
               | answer someone else, the right thing to do is to have all
               | the pieces in order for when an audit happens anyway)
        
               | MichaelZuo wrote:
               | Unless it's legally mandatory in such a way that superior
               | authorities can't overrule it, then it doesn't seem to
               | matter? (such as the President, appellate courts, etc...)
               | 
               | Clearly in this case Uber got a superior authority to do
               | so, and in any future case that will still be a
               | possibility.
        
               | tokinonagare wrote:
               | If a company is doing business here, the actual location
               | of file is irrelevant.
               | 
               | Also when the government is really motivated, he can
               | arrested the founders or executives directly (Pavel
               | Durov). Which is what they should do to Netflix execs if
               | they are doing business illegally.
        
               | gruez wrote:
               | >Also when the government is really motivated, he can
               | arrested the founders or executives directly (Pavel
               | Durov). Which is what they should do to Netflix execs if
               | they are doing business illegally.
               | 
               | You're in favor of holding executives hostage to demand
               | access to data? If they actually did something illegal,
               | they can be arrested/tried for that, but arresting
               | executives as a means to coerce companies into doing
               | stuff is a total perversion of the rule of law.
        
               | izacus wrote:
               | > You're in favor of holding executives hostage to demand
               | access to data? If they actually did something illegal,
               | they can be arrested/tried for that, but arresting
               | executives as a means to coerce companies into doing
               | stuff is a total perversion of the rule of law.
               | 
               | Turns out that witholding data as a company executive is
               | outright illegal, so yeah, we're in favor of it and they
               | can get arrested and charged for for it.
        
               | nerdbert wrote:
               | What if it is illegal to withhold the data during an
               | investigation? Isn't the executive then committing a
               | crime?
        
               | multjoy wrote:
               | The executives _are_ the company.
        
               | sealeck wrote:
               | > You're in favor of holding executives hostage to demand
               | access to data?
               | 
               | This is a very emotional way of saying "you're in favour
               | of enforcing contempt of court rulings against people who
               | try to obstruct the judicial process".
        
               | MichaelZuo wrote:
               | Irrelevant according to who?
        
               | aaronax wrote:
               | Thinking the systems that a company has are so sensitive
               | that the company is basically above the law is the insane
               | thing.
               | 
               | It is just a company--a group of people granted certain
               | rights. They have databases...fancy filing cabinets. Just
               | because the company is famous shouldn't preclude their
               | filing cabinets from being searched (presuming legal
               | processes are used and not abused).
        
               | gruez wrote:
               | > They have databases...fancy filing cabinets. Just
               | because the company is famous shouldn't preclude their
               | filing cabinets from being searched (presuming legal
               | processes are used and not abused).
               | 
               | That analogy doesn't work, because the "filing cabinets"
               | are actually sitting somewhere else, possibly in another
               | country/continent. It's not obvious that authorities in
               | one country has authority over documents stored in
               | another country.
        
               | valval wrote:
               | I and many others think the government should have 0
               | business in my filing cabinet. That difference in world
               | view might be what makes this topic more complex than you
               | seem to think.
        
               | Terr_ wrote:
               | [Not parent poster] So even the most heinous act of
               | violence become unprosecutable when the
               | suspects/accomplices have moved all remaining evidence
               | into a magically inviolable filing cabinet?
               | 
               | No? Then the world is a lot more complex than property
               | rights trumping everything else.
        
               | atoav wrote:
               | You are aware of the fact that tax evasion means these
               | companies are freeloading on the tax money the rest of us
               | (including: you) are paying? Especially in the case of
               | uber which is essentially using public infrastructure to
               | make their money having them pay taxes should be normal.
               | 
               | I agree that customer data needs to be protected, but it
               | is bold to assume that is the case at all with these
               | powerful corporate entities: if they lie to the state
               | when filing taxes what makes you believe they are ernest
               | when it comes to the protection of their users privacy?
               | 
               | Maybe it is a weird ideology I am holding here, but the
               | more powerful an entity is, the more transparent it
               | should become -- nowaday we got this completely reversed
               | with poor people being naked in front of the state and
               | big corps literally fooling everyone.
               | 
               | Edit: some also seem to think the state is the behemoth
               | that jumps on the poor little companies here. To that I
               | just have to think about the account of the German public
               | prosecutor Baumler-Hosl (of wirecard fame) where she told
               | about a raid on a bank where she and 4 collegues were
               | opposed by 130 (!) company lawyers.
        
               | haccount wrote:
               | The law was always there to step on the little man, the
               | VIPs always had it easier. Stop thinking too much about
               | it.
        
               | AnthonyMouse wrote:
               | > if they lie to the state when filing taxes
               | 
               | In general this is not what they do. What they do is read
               | the tax code carefully and structure their operations in
               | such a way as to minimize taxes, e.g. because tax is paid
               | on "profits" (revenues minus expenses) so they shift more
               | expenses into jurisdictions with high tax rates etc.,
               | causing "profits" to go down in those jurisdictions and
               | up somewhere else.
               | 
               | Then they don't pay any taxes in the jurisdictions with
               | higher tax rates and politicians go on TV and complain
               | about the companies following the laws that the
               | politicians enacted. Because if they actually fixed the
               | laws, the taxes would be paid based on the extent to
               | which the company does business in that jurisdiction, and
               | then companies could only avoid taxes by not doing
               | business there (costing the country jobs) or, for taxes
               | associated with local sales, by raising prices there.
               | Neither of which the politicians actually want to do, so
               | instead they pass laws that allow companies to avoid
               | taxes and then complain about it when the companies do
               | it.
        
               | pyrale wrote:
               | Uber has a history of serving falsified data to the
               | justice, though. Their offices are raided because they
               | can't be trusted with a subpoena.
        
               | golemotron wrote:
               | The real issue is that technology has rendered office
               | raiding useless. People are welcome to explore
               | alternatives.
        
               | pyrale wrote:
               | > People are welcome to explore alternatives.
               | 
               | For companies that deliberately obstruct justice work?
               | Have the board and a healthy amount of executives serve
               | 20 years in a high security prison, seize the assets and
               | investigate their investors' due dilligence process.
               | Gather proof with infiltrated workers.
               | 
               | Tech leaders need to learn that criminal conspiracy is
               | not part of a good business plan. If they start using
               | mafia tactics, so can Justice.
        
             | 0cf8612b2e1e wrote:
             | If you are a little person in the USA, I believe that would
             | be spoliation of evidence.
        
               | spellbaker wrote:
               | Ok I'll bite... wtf
        
               | telotortium wrote:
               | I don't think any of these kill switches involved
               | deleting data, just temporarily removing access of
               | systems in the affected office.
        
               | 0cf8612b2e1e wrote:
               | Not a lawyer, but let's say the cops were searching my
               | house. If I threw the keys to my unbreakable safe out the
               | window, such that they could never be found, I doubt a
               | judge would care for the distinction. That the evidence
               | exists but cannot be accessed is still going to find you
               | in contempt.
        
               | fossislife wrote:
               | As long as no police has confiscated (in most countries
               | this involves the police man touching it, I bet) the
               | equipment you can break it or make it inaccessibility
               | however you like. It's your stuff, after all.
        
               | mewse-hn wrote:
               | That metaphor doesn't seem directly applicable to cutting
               | off cloud access.
               | 
               | If we're trying for a metaphor that would be a similar
               | situation pre-digitization, the cloud servers containing
               | business documents could be considered head office, and
               | the office being raided would be the branch office. The
               | branch office would continually be communicating with
               | head office for their operations, and that communication
               | would be shut down during the raid.
               | 
               | This isn't a great metaphor because the "head office" has
               | become sort of stateless and ephemeral with digitization,
               | but that's part of the interesting question the OP was
               | posing, how does law enforcement collect evidence when
               | that evidence is hosted on cloud servers in nebulous
               | datacenters?
        
               | eastbound wrote:
               | By creating a law for seizing the IT system of a company.
               | "Provide everything", and if we later find that any other
               | document existed back at that time, then it's contempt of
               | court.
        
               | gruez wrote:
               | >By creating a law for seizing the IT system of a company
               | 
               | There's already "a law for seizing the IT system of a
               | company", it's called discovery or a subpoena.
        
               | telotortium wrote:
               | In the US such a law would likely be declared
               | unconstitutional by the fifth amendment due to being
               | overly broad:
               | 
               | """
               | 
               | United States v. Bridges, 344 F.3d 1010 (9th Cir. 2003)
               | 
               | There was probable cause to search the defendant's office
               | based on the information in the application that
               | documented his efforts to provide illegal tax advice to
               | various clients, including undercover agents. The search
               | warrant in this case, however, was overly broad. It
               | listed, among the items to be seized, "All records . . .
               | documents . . . computer hardware and software . . ."
               | Though this list was detailed, it was too expansive.
               | There was simply no boundary to what could be seized. In
               | addition, the warrant did not specify the crimes that
               | were the subject of the search (nor did the warrant
               | incorporate the application) so there was no limitation
               | in that manner. Though the application was detailed, the
               | warrant was not. All evidence should have been
               | suppressed. (No discussion of Leon).
               | 
               | """
               | 
               | https://casetext.com/analysis/search-and-seizure-
               | particulari...
        
               | stevekemp wrote:
               | What about if you're within 100 miles of a border?
        
               | svieira wrote:
               | Now let's say that instead you threw the keys to your
               | unbreakable safe to your friend across the Atlantic
               | Ocean. And you say that you didn't know that the people
               | entering were cops. And your friend won't give the keys
               | back. The evidence may exist, you cannot access it,
               | neither can the police. The court has no jurisdiction
               | over your friend and you have no authority to _force_
               | your friend to give you the keys back.
               | 
               | At that point, whether you are in contempt or not depends
               | on the answer to the question "did you know that the cops
               | were entering to look for evidence before you threw the
               | keys?" Whether the judge _holds_ you in contempt or not
               | is a function of the free choice of the judge and is not
               | related to the answer to the first question (though
               | whether or not the judge _should_ hold you in contempt is
               | a function of what the judge believes about what you
               | believed).
        
               | jjallen wrote:
               | This is like not giving them the password to your phone
               | which I thought was protected at least in the US. They're
               | both literally keys.
        
               | onlypassingthru wrote:
               | Your password is sort of protected. A judge can hold you
               | in prison for contempt for refusing to provide a password
               | but there is an 18 month jail limit, at least in federal
               | court.[0]
               | 
               | [0]https://arstechnica.com/tech-policy/2020/02/man-who-
               | refused-...
        
               | telotortium wrote:
               | The keys still exist and are accessible. What the kill
               | switches does is make a fishing expedition harder. If the
               | police knew of the existence of a specific document, or
               | even all documents pertaining to certain terms, they
               | could issue a targeted subpoena which Uber would have to
               | comply with (at least in the US).
        
               | tonygiorgio wrote:
               | If it were keys to a safe that existed outside of the
               | warrant requirements (in another country in fact), then
               | it would likely not be illegal. The regulators would
               | unlikely be able to legally access that safe anyways
               | without extra due process, so it's mostly about
               | protecting against unwarranted access.
        
               | Onavo wrote:
               | Do the folks at Brussels have the concept of "fruit of
               | the poisoned tree" and parallel construction?
        
               | izacus wrote:
               | Stop mixing up law which governs corporate entities and
               | criminal law that touches individuals.
        
               | Onavo wrote:
               | Same crap, different flavor.
        
               | atmosx wrote:
               | > I doubt a judge would care for the distinction.
               | 
               | If the judge receives a call from the ministry of
               | justice, they will care a great deal about the
               | distinction.
        
               | izacus wrote:
               | This theorycrafting is cute, but in reality you've mixed
               | up corporate entities and yourself as a person in a
               | criminal case.
               | 
               | And if a corporate entity finds a way to openly defy a
               | national government, it tends to happen that those
               | governments find a way to change the law (they're the
               | ones making it, right? :P) for that defiance to become
               | punishable by other parts of those governments which can
               | sanction the corporation, prevent their operations within
               | the country or even throw people in jail.
        
               | AnthonyMouse wrote:
               | You're conflating two different things here.
               | 
               | One is, what does the law say? Did they violate it? Is it
               | illegal for a foreign subsidiary to temporarily shut off
               | access to a branch office? How would we like this to
               | work? Policy arguments about law enforcement vs. due
               | process and government overreach.
               | 
               | The other is, politics. If the local government is
               | captured by a cartel of taxi medallion holders who don't
               | like Uber, the government is going to find a way to screw
               | Uber, regardless of whether Uber is complying with
               | existing law. But then it's politics and Uber is a multi-
               | billion dollar corporation, so they have the option to
               | capture the government themselves.
               | 
               | Of course, that leaves the meta argument. Maybe deciding
               | what should happen based on the second method is worse
               | than the first, so how do we prevent that from being what
               | happens?
        
               | throwawaymobule wrote:
               | Even if you do it before you could have known you were
               | being served a warrant?
               | 
               | IIRC, they did it in the US too.
        
             | exe34 wrote:
             | you'd think a judge could order you to provide the
             | documents and then jail you for contempt of court until you
             | do?
        
           | sensanaty wrote:
           | How the hell can any of what you just described be legal?
           | 
           | Do you have any articles about this? Because this is _insane_
           | if true.
        
             | YetAnotherNick wrote:
             | Why should it be illegal? Isn't it akin to "right to remain
             | silent"? Why the need to present any information to police
             | unless it is asked by court. Assuming that they didn't
             | delete the data, just moved it to somewhere safe where it
             | couldn't directly be taken away.
             | 
             | We had a raid in one of my previous company due to
             | copyright violation due to a user uploaded content.
             | Authorities came in to take in all the codebase, reports
             | and even employee devices. Basically once given court
             | permission, police would try to collect all the unrelated
             | things which could be taken in the permission, so that they
             | could extort you later.
        
               | LunaSea wrote:
               | It can be destruction of evidence, which is illegal.
        
               | staticautomatic wrote:
               | Unless it wasn't destroyed, in which case it might be
               | interring with an investigation, which is probably also
               | illegal in France.
        
               | Algent wrote:
               | It's definitely interference/obstruction at least of the
               | raid itself yeah, but looking at the text and not being a
               | lawyer I have a feeling it may be extremely hard to
               | prosecute for something more substantial than a fine low
               | enough for a french exec have it a as a guaranteed
               | expense (bnEUR in tax fraud vs a few kEUR in fine). The
               | law does also mention prison but it's not the kind of
               | stuff that ever end up being applied for fiscal related
               | cases.
        
               | krisoft wrote:
               | > I have a feeling it may be extremely hard to prosecute
               | for something more substantial than a fine low enough for
               | a french exec have it a as a guaranteed expense
               | 
               | I know nothing about French law, but this whole thing
               | gives me "organised crime" vibes. In many jurisdictions
               | the punishment dramatically increases when a crime is
               | commited as an organised group whose purpose is to commit
               | said crime. As i said i know nothing about French law so
               | i don't know if the same concept is present there, let
               | alone if the letter of the law would fit the situation.
               | 
               | But yeah i agree with you they won't care unless they are
               | sitting in a cell with the chance of sitting a lot more
               | in a cell.
        
               | _bin_ wrote:
               | Denying access to data that could still be specifically
               | subpoenaed isn't destruction of evidence, it's a normal
               | security measure. They still have the warrant to search
               | everything _in the office_ , but not the right to use
               | those computers to access uber's entire worldwide
               | infrastructure.
               | 
               | I have no idea what french law says about it but I think
               | it's morally fine and don't care that uber did it.
        
               | dh2022 wrote:
               | I think this is an example of law lagging technology. A
               | warrant gives the police the right to inspect and seize
               | contents of a safe inside a house. Similarly, the law
               | should be updated so that a warrant gives the police the
               | right to inspect and seize contents of local computers.
               | Local computers surely have valid certificates that allow
               | the computers to connect to the mothership, right?
        
               | dmurray wrote:
               | Does a search warrant for your house give the police the
               | right to search your car, if they found your car keys in
               | your house? What about your neighbour's or your
               | employer's car - perhaps on the other side of the world -
               | if you happened to have those keys? To compel you not to
               | tell your employer to change the locks, so the seized
               | keys won't work?
               | 
               | These seem like closer real-world analogies for what
               | exactly a warrant to search someone's computer should
               | entitle the police to do.
        
               | pjerem wrote:
               | Your analogy doesn't work. Your neighbor is not you.
               | 
               | $COMPANY is $COMPANY all around the world and if $COMPANY
               | wants to do business in $COUNTRY (which is not an
               | obligation, they choose to), then yes, they have to
               | entirely cooperate with $COUNTRY.
               | 
               | If they don't want to, they can still do business
               | elsewhere.
        
               | Dylan16807 wrote:
               | I don't think a warrant to search an office should let
               | them use the keys they find there on a company truck five
               | miles away, either. Despite being the same company. (If
               | it's in the parking lot then it's a maybe.)
        
               | AnthonyMouse wrote:
               | > $COMPANY is $COMPANY all around the world
               | 
               | This is the thing which is not the case. The subsidiary
               | in the US is nearly always a _different company_ than the
               | one(s) in Europe. They 'll have different management and
               | different lawyers etc. Sometimes they even have different
               | owners, e.g. because one of them is a joint venture with
               | some other company, or a franchise. And they have to be
               | different, because different countries have different
               | laws and those laws often conflict with each other. So
               | the subsidiary in the US follows US law and the one in
               | France follows the law in France.
               | 
               | You could try to make it otherwise, but it's pretty
               | obvious what would happen then. Companies couldn't
               | formally operate in multiple countries because their laws
               | are incompatible, so instead there would be a straw front
               | company in any given country that nominally isn't owned
               | by the conglomerate, but is effectively just reselling
               | their product/service in that country for an additional
               | margin that only pays the salary of local management. To
               | prevent this you would have to ban companies from having
               | foreign suppliers, which is not very practical.
               | 
               | And since countries know that's what would happen, they
               | allow foreign subsidiaries to be regarded as separate
               | entities even if they have shared ownership, instead of
               | demanding the charade.
        
               | pjerem wrote:
               | In absolute, I agree with you. But personally if I had to
               | chose between tax evasion (permitted by those schemes)
               | and having less multinational companies because it'd be
               | more difficult... well, my country was doing pretty okay
               | before multinationals and is not doing okay since every
               | taxes are evaded.
               | 
               | Well Netflix is nice and all but I prefer social security
               | and teachers in school.
        
               | AnthonyMouse wrote:
               | Federal revenue as a percent of GDP:
               | 
               | https://fred.stlouisfed.org/series/FYFRGDA188S
               | 
               | Basically flat since the end of WWII, significantly
               | _lower_ before the war. At the height of the New Deal,
               | less than half of what it is now. And that 's in the face
               | of significant growth in real GDP per capita. Probably
               | not a dissimilar story in most other Western countries.
               | 
               | The problem isn't in the amount of taxes being collected,
               | it's in where the money is going.
        
               | _bin_ wrote:
               | Not necessarily. Depending on how the org's set up, the
               | system may be permissioned to access too much stuff. I
               | think justice systems should lean less on a general
               | warrant - too much of a fishing expedition - and instead
               | focus on subpoenas specifically related to their area of
               | investigation. E.g. if they seize the CEO's computer on
               | accounting or tax concerns, I sincerely doubt they showed
               | a judge probable cause to seize, I don't know, new
               | product designs. As such they should not be able to
               | access them.
        
               | sidewndr46 wrote:
               | The point you're making is valid, but also exposes a
               | common theme in litigation against big tech. It's pretty
               | common to hear something like "company XYZ used data ABC
               | to train a model about their users and is court ordered
               | to delete it". It's unlikely that anyone in the justice
               | system has even the slightest clue how to ascertain if
               | this actually happened and certainly no way to prove it
               | has been deleted. The court gives the order, the company
               | says they have complied, & everyone pretends to go back
               | to the way things were before hand.
        
               | sidewndr46 wrote:
               | let me just extrapolate this out a bit for you. I live in
               | the US (yes I visited France once long ago, it was nice).
               | I use Uber. My phone is an Android phone running Uber's
               | app.
               | 
               | Can a French prosecutor use Uber's systems to deliver a
               | malicious payload to my phone to gather evidence? If so,
               | is Uber required to assist them in this task?
        
               | BolexNOLA wrote:
               | I just have a hard time believing that any of us could
               | get away with that.
        
               | _bin_ wrote:
               | Wasn't half of the concern with the arrest of Ross
               | Ulbricht figuring when they could get him with his
               | computer unlocked, without time to lock/wipe it? They'd
               | have a pretty hard time proving destruction of evidence
               | if 1. they didn't know for sure evidence was on _that_
               | specific computer and 2. it was destroyed rather than
               | just that the decryption key was removed from memory.
               | 
               | Regardless, the government violating an individual's
               | rights doesn't mean we should yell at uber, it means we
               | should yell at the government.
        
               | chollida1 wrote:
               | These two issues are very far apart.
               | 
               | Ross could argue he forgot his password to unlock the
               | data in a single users case.
               | 
               | In the corporate case it would be hard for Uber to argue
               | that the entire company now has no access to any of the
               | subpoenaed data.
        
               | BolexNOLA wrote:
               | Yeah that doesn't really shift my opinion lol If I
               | activated a kill switch to wipe my local computers when
               | the FBI entered my house I can't even imagine the hell
               | I'd reap, let alone that my data would be safe because
               | it's scattered on servers in other countries.
               | 
               | Also we can claim whatever we want but that doesn't mean
               | it'll protect us in court.
        
               | sensanaty wrote:
               | Presumably the French police aren't randomly deciding on
               | a Tuesday for no reason to check the company for proof of
               | them being tax cheats without some court somewhere
               | requesting it, but even if they were, we're talking about
               | a company here, not a person. A person has the right to
               | remain silent, it doesn't make sense for a company to
               | have that same right.
               | 
               | And the 2nd half just reads like pure corruption to me,
               | they paid off some politician (who just so happens to
               | wield the most power in the whole country) to pressure
               | him to get them to stop their investigation into their
               | illegal acts? In what universe could that 2nd sentence be
               | construed as anything other than slimy, corrupt behavior?
        
               | YetAnotherNick wrote:
               | > And the 2nd half just reads like pure corruption to me
               | 
               | Why did you conclude that?
               | 
               | There were some user uploaded pirated content in our
               | platform. As far as I know, some media company won
               | approval by some judge for a raid to discover the extent
               | of piracy. It's just in the police rulebook to get
               | everything during the raid where there could be pirated
               | content, including employees laptops.
        
               | electrozav wrote:
               | And if raids are court ordered?
        
               | dh2022 wrote:
               | I assume when the office was raided there was a warrant
               | that would give police the right to inspect and seize
               | property...
        
               | spacemanspiff01 wrote:
               | My impression was that they were trying to get remote
               | access to ubers US servers/infrastructure/data?
               | 
               | Might be wrong...
        
               | chollida1 wrote:
               | Because the government already has a warrant to obtain
               | this evidence(they can't raid the office otherwise) and
               | you as the company pushing this button are failing to
               | turn over that evidence.
        
               | charlieyu1 wrote:
               | I guess locally encrypted files in my computer is a
               | problem as well then
        
               | alexey-salmin wrote:
               | In many jurisdictions it actually is a problem
               | 
               | https://en.m.wikipedia.org/wiki/Key_disclosure_law
        
               | ExoticPearTree wrote:
               | It doesn't work like that.
               | 
               | The warrant is based on probable cause, meaning that law
               | enforcement is very confident in what they will find. So,
               | if they don't find anything, tough luck. You have
               | absoluteley no obligation to help the prosecutors in any
               | way.
               | 
               | The single notable exception that I am aware is the UK
               | where you don't have the right to not incriminate
               | yourself and if you don't provide a password to am
               | encrypted device you can be jailed until you do.
        
               | echoangle wrote:
               | You have a right to not help them, but you can't actively
               | destroy evidence. Do you think it would be fine to begin
               | burning documents once the police comes to you office?
        
             | barrenko wrote:
             | It kinda sounds like you can't raid Uber / Netflix without
             | hackers, Ghost in the shell type raid. Which is probably
             | the future of raids.
        
               | andylynch wrote:
               | This is one of the prime threat models for things like
               | encryption of data at rest on servers
        
           | Izikiel43 wrote:
           | That's so interesting, probably a good move for them, it's
           | not their job to make governments lives easier
        
           | jokoon wrote:
           | do you have a source for the "kill switch"?
        
         | badpun wrote:
         | The authorities asks for access to these online documents?
         | Similarly to how they ask to access to physical documents (they
         | don't break down doors and break locks on file cabinets). If
         | the personel of the company does not disclose some of the
         | online documents, and these documents come up later (e.g.
         | because they are referenced in some of the documents that did
         | get disclosed), the people who did it get charged with
         | tampering with an tax investigation.
        
         | croes wrote:
         | They just demand the data per warrant and if you don't deliver
         | you go to jail for obstruction of justice
        
           | red_trumpet wrote:
           | Is that true? I'm not a lawyer but AFAIU, you don't have to
           | provide incriminating evidence against yourself?
        
             | bogeholm wrote:
             | It's more or less the dictionary definition of 'subpoena'
             | eg. [0]:
             | 
             | > under penalty (you shall bring with you)
             | 
             | [0]: https://www.merriam-
             | webster.com/dictionary/subpoena%20duces%...
        
             | croes wrote:
             | The IT guys aren't the ones under investigation.
        
           | gruez wrote:
           | How does that work if it's a cloud system and you're denied
           | access because the IT admin from another continent locked you
           | out? Are you going to keep the executive around as a hostage
           | in hopes of getting them to release the files?
        
             | arccy wrote:
             | yes? that's why countries require human presence
        
             | croes wrote:
             | Why should the IT guy lock you out if you want to access
             | your data?
        
         | cynicalsecurity wrote:
         | What a funny naive thinki. Cloud services don't protect from
         | the official authorities. Unless you want to go to jail.
        
       | schnitzelstoat wrote:
       | Is this what Emily was doing in Paris?
        
         | drooopy wrote:
         | Emily moves from Paris to Rome and then this happens.
         | Coincidence?
        
           | dylan604 wrote:
           | Does Emily store all of her boxes of important documents in
           | the spare bathroom too?
        
           | CodinM wrote:
           | did you literally just spoil this for me
        
             | IncreasePosts wrote:
             | It's been out for 2 months, you had your chance
        
             | vulcan01 wrote:
             | President Macron spoiled this for everyone in an interview
             | with Variety.
        
       | dvorack101 wrote:
       | Wel,
       | 
       | But things are changing. It seems... These are the developments
       | in The Netherlands. Most of it somewhere over the horizon.
       | Interested to know if other countries with similar tax evasion
       | rules change their rules?
       | 
       | It's in dutch so use your popular translation tool for these
       | links:
       | 
       | - https://www.rijksoverheid.nl/documenten/brochures/2023/10/11...
       | - https://theses.ubn.ru.nl/server/api/core/bitstreams/a384a151...
       | - https://open.overheid.nl/documenten/44e45809-c66e-4378-9fc8-...
       | - https://www.nu.nl/economie/6286473/nederland-nummer-een-bij-...
        
       | I_am_tiberius wrote:
       | I know I'm likely alone in this opinion, but corporate income tax
       | seems like a poorly designed tax to me. Why should companies pay
       | taxes in a year with high profits, even if they face losses for
       | the next ten years? Why should I pay corporate income tax when
       | dividends and income are taxed anyway? Corporate income tax also
       | seems to heavily influence business strategies as a consequence,
       | which wasn't its intended purpose.
        
         | jaimsam wrote:
         | A lot of words to say: taxation is theft.
        
         | tnolet wrote:
         | The world of tax is complex. Business exist in many shapes and
         | sizes. So...
         | 
         | - because companies heavily use government resources like roads
         | and stuff.
         | 
         | - because losses can be offset against profits. These tend to
         | be middled out over multiple years. You can port losses to
         | other years.
         | 
         | - a lot of companies (holdings etc.) don't pay out income tax
         | and are basically just letterbox companies. These companies
         | need to pay tax on dividends otherwise they would literally pay
         | zero tax.
        
           | I_am_tiberius wrote:
           | > - because losses can be offset against profits. These tend
           | to be middled out over multiple years. You can port losses to
           | other years.
           | 
           | These losses expire (different from country to country)!!
           | Plus, inflation is not taken into account.
           | 
           | > a lot of companies (holdings etc.) don't pay out income tax
           | and are basically just letterbox companies. These companies
           | need to pay tax on dividends otherwise they would literally
           | pay zero tax.
           | 
           | Tax on dividends is not corporate income tax. Dividend tax is
           | classified as capital gains tax, which is entirely separate.
           | My point is that anyone taking out money must pay taxes
           | through personal income tax or dividend tax. So corporate
           | income tax is just money that would be taxed anyway - or
           | invested/used by the company. So no real purpose other than
           | producing another cash inflow for the government.
        
         | closeparen wrote:
         | Whether you earn and save a given dollar as a W2 worker or
         | through a business you own seems pretty incidental, right? Your
         | net worth is going up just the same; society has the same
         | interest in containing inequality.
        
         | sensanaty wrote:
         | Why shouldn't companies pay taxes? Especially since income is
         | taxed already and your average Joe gets screwed way more than
         | the poor downtrodden billion dollar companies.
        
           | I_am_tiberius wrote:
           | Because a company just invests the money. You can't take out
           | money from a company as an owner without taxing it anyway
           | (because you anyway have to pay capital gains tax / personal
           | income tax). My point was that I don't see a point in having
           | corporate income tax (that's just an additional tax that
           | prevents companies from investing in the business and
           | employees).
        
             | immibis wrote:
             | "Invests the money" means it sits in their bank account
             | until they've convinced enough politicians that the money
             | should be taxed as it comes into the company, not when it
             | goes out, and then they issue a massive dividend.
        
         | binary_slinger wrote:
         | Because governments need money to fund services. They would put
         | a tax on making HN comments if they could get away with it.
        
           | betaby wrote:
           | Link tax is a thing in some countries. HN is just to small to
           | be taxed.
        
         | aithrowawaycomm wrote:
         | Any corporation uses roads, mail, police, courts, and other
         | public services, and this usage is not offset by individual
         | income taxes on that corporation's employees, since the
         | employees also use these things. In fact I suspect more
         | resources are spent on serving corporations than serving
         | individual taxpayers - with the important caveat that I am
         | specifically excluding government social insurance programs.
         | But those are often a totally separate tax system.
         | 
         | It is baffling to think that for-profit corporations should be
         | allowed to use public services without paying for them: before
         | a company makes further internal investments with new revenue,
         | it should chip in to society for building the infrastructure
         | that made the revenue possible. A corporate income tax is
         | perfectly natural.
        
       | bubbleRefuge wrote:
       | How about just get rid of double taxation in corporate taxes?
       | Eventually, taxes will get paid via distributions or sale of
       | stock by individuals.
        
         | Retric wrote:
         | Or never if the stock is owned by a foreign national, charity,
         | sovereign wealth fund, etc.
         | 
         | Reasonable corporate taxes are a net positive for the economy
         | of the county that issues them.
        
         | lokar wrote:
         | Everything is double, triple, etc taxed. The corp->shareholder
         | thing is an arbitrary point to focus on.
         | 
         | Some amount of revenue must be raised. Suggest an alternative.
         | Not taxing corp profits will result is less overall tax income
         | (it wont be made up in shareholder taxes).
        
         | knallfrosch wrote:
         | You do know my income has already been taxed? Why am I paying
         | double tax when buying alcohol? Why is my income taxed when the
         | companies revenues were already taxed?
         | 
         | There is no double taxation. Transactions are taxed, not money.
        
         | mindslight wrote:
         | Why not advocate for taxing only corporations, rather than the
         | more oppressive direction of taxing only humans? Corporations
         | intrinsically run on accounting report paperwork, meaning tax
         | forms are an incremental cost rather than a novel burden. And
         | they receive massive benefits from the state - liability
         | protection, outsized access to the legal system, and often
         | direct subsidies.
        
           | precommunicator wrote:
           | Because corporate taxes are paid on profit (revenue-
           | expenses). So as a company I can claim a lot of stuff as a
           | expenses. Executive salaries? Anything left after that? Lemme
           | quickly create a separate company in some low tax
           | jurisdiction and pay them for marketing expenses, and
           | suddenly I have no profits, and nothing to tax. Regular
           | people can't do that.
           | 
           | You also generally can't tax the revenue instead of profits
           | (except perhaps few percent of revenue as the minimal tax),
           | because different companies have hugely different amounts of
           | revenue and expenses.
        
             | mindslight wrote:
             | None of that is really a show stopper when talking about an
             | overhaul of the tax system and what it targets.
             | 
             | Speaking of taxing revenue instead of profits, that's
             | another reason the current tax regime is so galling (at
             | least speaking from a USian perspective). Individuals
             | essentially _are_ taxed on revenue and can 't deduct things
             | that would otherwise be straightforward deductions in a
             | business context, as necessary and proper expenses required
             | to earn that revenue.
        
         | ianburrell wrote:
         | Then you would be in favor of only taxing retained profits.
         | Corporations keep piles of money for future use. It would make
         | sense to allow deductions for dividends distributed to
         | shareholders. But could also fix the stock buyback loophole by
         | not allow deduction.
        
       | phendrenad2 wrote:
       | As a non-European, it seems like these raids happen regularly to
       | large companies' offices in Europe (mostly US companies). Maybe
       | some Europeans can chime in and answer something that's been
       | bothering me: Does this happen to smaller companies, too? Is it a
       | serious problem to getting work done, not knowing if regulators
       | are going to shut you down and rifle through your filing
       | cabinets?
        
         | knallfrosch wrote:
         | A raid is a lot of work and only happens when you know you find
         | something.
         | 
         | For 99,9% of companies, you get audited every 5--25 years by
         | getting a visit from your local tax authority.
         | 
         | Remember: Small/medium companies have comparable companies and
         | you can easily spot the tax dodgers. Or tax dodging is
         | unofficially tolerated to some degree -- think restaurants only
         | accepting cash.
         | 
         | Most companies are not as blatantly illegal as Uber..
        
         | immibis wrote:
         | Large multinational companies are accustomed to openly breaking
         | the law and getting away with it in the USA; when they try to
         | do the same in Europe they are very surprised when the law
         | actually comes after them.
         | 
         | They also raid anyone else they don't like, such as people who
         | run Tor exit nodes... but random small businesses are not in
         | that group.
        
           | lacy_tinpot wrote:
           | Maybe this explains why the US is out ahead in GDP, income,
           | and is doing much better pre and post covid than Europe.
           | 
           | It's not so much breaking laws, but unnecessary restrictions
           | and harassment by Europeans states.
           | 
           | The US is business friendly. It's industry friendly. We don't
           | needlessly harass the business of sovereign individuals, and
           | the state apparatus isn't being used as an excuse as to exert
           | power or influence over the population. Not to the same
           | paternalistic extent of Europe.
           | 
           | In Europe the liberal state apparatus that replaced the
           | monarchies are acting an awful lot like the monarchies.
        
             | sapphire42 wrote:
             | You call a tax fraud investigation "needlessly harassing
             | the business of sovereign individuals?"
             | 
             | You're right, the U.S. is very business and industry
             | friendly, which explains why the American people have been
             | getting poorer and poorer while corporations and their
             | shareholders get richer and richer.
        
               | lacy_tinpot wrote:
               | Who do you think the corporations are? Who do you think
               | the small businesses are? Usurping the free enterprise of
               | the American people and selling it as "freedom" is a sly
               | tactic. Those industries, those corporation, those
               | businesses ARE the American people.
               | 
               | The government can never ever actually represent the
               | people. It cannot act in the best interest of the people.
               | 
               | You know why?
               | 
               | Because it's made of people, and those people can only
               | act in the best interest of themselves. They will never
               | ever act in the best interest of other people, because
               | people physically cannot.
               | 
               | So why are Americans getting "poorer"
               | 
               | Well they're not. This is absolutely false. The American
               | people are getting richer. The American people have a
               | widening wealth gap, but that is far from increasing
               | poverty.
               | 
               | That increasing wealth gap is due to restrictions imposed
               | by enlightened bureaucrats on people getting wealthy, in
               | collusion with the old money old industry extremely
               | wealthy incumbents.
               | 
               | In other words the State apparatus is hijacked by the
               | incumbents that assume their survival is the survival the
               | American people, hence they are "public". That state
               | apparatus will never ever attempt to dismantle the very
               | thing that feeds it.
               | 
               | That's why it hates newcomers and that's why the state
               | apparatus must go.
        
               | immibis wrote:
               | Take a walk around San Francisco and then say poverty
               | isn't a problem.
        
               | lacy_tinpot wrote:
               | You know how much is spent on keeping San Francisco
               | looking poor?
               | 
               | "Non-profits" are spending literal billions of dollars on
               | the problem... so that it remains a problem rather.
        
               | mianos wrote:
               | Americans have been getting richer and richer according
               | to most recent studies. At the same time, other socialist
               | countries are getting, on average, poorer. I think you
               | may be confusing social inequality with overall wealth.
        
               | overstay8930 wrote:
               | The Average American is getting richer and richer,
               | especially compared to European wage stagnation. I don't
               | think non-Americans understand how rich middle class
               | americans are.
        
               | lomase wrote:
               | Only 50% of Americans have Passports. 80% in Europe.
               | 
               | We understand it, because we travel there on, our paid,
               | vacations.
               | 
               | My last time in America I went to San Francisco, lots of
               | money, I have not seen a worst place to live in my life.
               | 
               | Americans don't understand the quality of life other
               | places have.
        
               | lacy_tinpot wrote:
               | And other places don't understand the sheer amount of
               | wealth and freedom other people have. "It costs a lot of
               | money to look this cheap" and San Francisco spends
               | billions to look that cheap btw.
               | 
               | Especially Europe. Europeans don't even seem to
               | understand how large America is, which is why so few have
               | passports.
        
             | undersuit wrote:
             | As an American surrounded by Superfund sites I would like
             | some of these unnecessary restrictions and harassment by
             | the state. The US is so beholden to private interests we
             | can't even repair the roads or mandate healthcare without
             | making it into a market.
        
               | lacy_tinpot wrote:
               | Do you know how we won World War 2? We retooled our
               | industrial base because we had strong private sector
               | industries. Do you know how the railroad infrastructure
               | was built? We incentivized private sector industrial
               | scale corporations to build out the railway. Guess how
               | the roads in the country were built/who advocated for
               | them in the first place.
               | 
               | Do you know who the industrialists are? They are the
               | people of the United States. The industry IS the public.
               | 
               | That's why the US has so many millionaires. And that's
               | why Europe is such a failure.
               | 
               | The US IS "beholden to private interests", because the
               | CITIZENRY is itself the "private interests".
               | 
               | In other words that term "beholden to private interests"
               | is in contrast to "beholden to public interest". The
               | later "public" does not mean citizens or the people, but
               | is a dog whistle for the exact opposite, that is the rule
               | by an oligarchic "enlightened bureaucrats" that colludes
               | with industries that has a sad case of mistaken
               | identities, and narcissistically associates its survival,
               | its wellbeing, with the public. When in fact it is the
               | abuser of the public.
               | 
               | The reason the "private" is the "private" is to protect
               | the American citizen from government.
        
               | inkcapmushroom wrote:
               | >Do you know how the railroad infrastructure was built?
               | 
               | Abusing the heck out of immigrants and genociding the
               | native people, I'm pretty sure. Also this (link is https:
               | //www.digitalhistory.uh.edu/disp_textbook.cfm?smtID=2&...
               | ):
               | 
               | >Construction of the railroad provided many opportunities
               | for financial chicanery, corruption, graft, and bribery.
               | The greatest financial scandal of the 19th century grew
               | out of the railroad's construction. The president of the
               | Union Pacific helped found a construction company, called
               | Credit Mobilier, which allowed investors, including
               | several members of Congress, to grant lucrative
               | construction contracts to themselves, while nearly
               | bankrupting the railroad.
               | 
               | I don't think the corporation/government good/evil
               | dichotomy you have made is so clean cut.
        
               | lacy_tinpot wrote:
               | "several members of Congress, to grant lucrative
               | construction contracts"
               | 
               | The difference is that I see that part as the evil. As in
               | who is the "corrupt", "graft" and "bribery" here
               | referring to? It's the government.
        
               | undersuit wrote:
               | >Do you know how we won World War 2?
               | 
               | We as in the Allied forces? The Great Alliance?
               | 
               | I also live within 200 miles of one of our Japanese
               | Internment Camps.
        
               | lacy_tinpot wrote:
               | It was America's industrial base that won the war. This
               | is an absolute fact. To deny it is like denying that
               | American tanks, trucks, guns, bullets, engines, etc. won
               | the war or that they were made by the American
               | government.
               | 
               | They weren't. America's industrial base, its _people_ ,
               | came together and retooled themselves for this singular
               | effort.
               | 
               | In other words the labor and industry of the American
               | people was co-opted by the government. It turns out it's
               | been co-opted for so long the government's begun to think
               | of itself as the people. The entire point is that the
               | government is not the people and can never ever be the
               | people.
               | 
               | That's the basis of the very existence of America.
               | 
               | The Nazis hated America for its industrial base btw. It
               | saw the capitalist machine as itself immoral.
        
               | pezezin wrote:
               | > Do you know how we won World War 2?
               | 
               | https://en.wikipedia.org/wiki/Raising_a_Flag_over_the_Rei
               | chs...
               | 
               | I don't see any American flag here.
        
               | lacy_tinpot wrote:
               | Who do you think supplied the Russian? Maybe they won by
               | throwing pebbles and using horse-drawn chariots?
               | 
               | Lend-Lease. Who do you think they leased from and what do
               | you think they leased?
        
         | Etheryte wrote:
         | Getting raided can happen to companies of any size, Mullvad
         | comes to mind as an example of a company that's small, European
         | and got raided, but it is incredibly rare. It's hard to
         | overstate how exceptional it is, you need to either be on the
         | police radar with a serious issue, or breaking the tax law
         | considerably, or etc. I think the main reason you see this
         | happen to a lot of American companies is that they expand to
         | Europe, but try to do business the same way they did back home.
         | Both the legal landscape and the moral landscape wrt it are
         | very different in Europe, and trying to willingly evade taxes
         | for example is tended to with a very heavy hand. If I'm not
         | mistaken, that's what's happened to Netflix here: they already
         | got caught evading taxes once, and now there's a suspicion that
         | they're doing it again/still.
        
       | johndhi wrote:
       | Sounds like the tech companies won't be expanding outside of
       | Ireland for a while ....
        
         | alexey-salmin wrote:
         | Well they certainly do want the revenues from users outside of
         | Ireland
        
           | johndhi wrote:
           | People with guns forcibly going through your things with
           | threat of prison time tends to erase desire for revenue. See
           | international business climate in China.
        
             | pas wrote:
             | Around ~2012 we were chilling on the terrace of a fancy
             | office in the brisk morning (after a quick server migration
             | in the datacenter on the ground floor, which of course
             | turned into an all-nighter) as people were coming in to
             | work, and then suddenly the folks coming in all looked the
             | same, greenish uniform, some had SMGs, oh well.
             | 
             | We worked for a small company, so we knew that they're here
             | for the big company that does credit card transactions, but
             | it was both surprising and ... absolutely uneventful, they
             | didn't even talk to us. (As we were leaving we didn't even
             | run into them - at least I don't recall any interaction.)
             | 
             | Later the sysadmins of the big company had amazing stories
             | about how the tax authorities wanted copies of every hard
             | drive. And when they told them that, sure, sure, but things
             | are on a RAID and without the config and the card it'll be
             | useless. They didn't care of course :)
        
         | scoofy wrote:
         | I mean I think the point of the story is that they are
         | pretending not to.
        
       | bgnn wrote:
       | Dutch are extremely business friendly with streamlined simple
       | bureaucracy but they won't tolerate tax evasion. The correct
       | approach would be to negotiate with the tax service.
        
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