Does Starbucks Pay Enough Tax?
Rachel Griffith
24 November 2015

http://live.wavecast.co/does-starbucks-pay-enough-tax/

In 2012 Starbucks became a target for public protests
• Starbucks had paid very little corporate income tax since it entered the UK market in 1998
• Starbucks declared zero profits (and therefore zero tax payments) in most years in the UK

Last month controversy over Facebook’s tax affairs
• Facebook paid £4327 in UK corporate income tax
• One Direction paid £8.2m in UK corporate income tax

Concern that firms aren’t paying a “fair share” of tax
• The media has widely reported on the strategies that companies use to avoid tax
• “companies need to wake up and smell the coffee”
David Cameron, Prime Minister
• “We will force people like Starbucks, Vodafone, Amazon and
Google and all the others to pay their fair share of taxes.”
John McDonnell, Shadow Chancellor
• International government organisations such as the OECD are trying to reach agreement over new rules for the taxation of multinational firms

Does Starbucks Pay Enough Tax?
• Starbucks had paid very little corporate income tax since it entered the UK market in 1998
• Starbucks declared zero profits (and therefore zero tax payments) in the UK in most years up to 2012

This talk
• What is a “fair” share of tax?
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Who bears the burden of corporate income taxes?
Why the recent increase in concern over corporate income taxes?
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• greater reliance on ideas (intangible assets) greater international mobility of activity
• How much tax should firms pay?
• Where should they pay it?

How much corporate income tax do firms pay in the UK?
• Corporate income taxes account for around 7% of total tax revenues
• Revenue pretty stable even though UK corporate income tax rate has fallen from 52% in 1980 to 20% in 2015

What is a “fair” share of tax?
• “Fairness” is not a property of a specific tax
• it is a property of a tax (and benefit) system

Distributional impact of the UK tax and benefit system in
2009-10, excluding ‘business taxes’
Adams and Browne, 2010, IFS
Source:

What is a “fair” share of tax?
• “Fairness” is not a property of a specific tax
• it is a property of a tax (and benefit) system
• Fair relative to what?
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• relative to your income?
relative to how much of publicly provided goods the firm uses?
relative to what competitor firms pay in tax?
relative to other “people”?

Who bears the burden of the corporate income tax?
• Legal incidence
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• legally “the firm” pays the tax to the Inland Revenue in fact firms pay most taxes in this sense
• Economic incidence :
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• who is made worse off because of the tax firms can not bear the economic incidence of a tax, they can not be made worse off, only people can
• Economic incidence can be very different from legal incidence

The basics of how corporate income tax works
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Your mother gives you $10 to open a lemonade stand
You spend the $10 on
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• lemons ($1) sugar ($1) a pitcher ($3) cups ($2) wages ($3)
• You sell 50 cups at $0.25
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• costs were $0.20 per cup
50*0.20 = $10.00
income is 50*0.25 = $12.50
profits are $2.50
which go back to your mum as a dividend

The basics of how corporate income tax works
• Now the government introduces a corporate income tax at
40%
• This means you pay 40% of your profits to the government
• 40% of $2.50 = $1.00
• Who pays for this?
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• does your mum accept a reduced dividend of $1.50
do you accept a lower wage of $2.00
do you charge a higher price of $0.27
• The answer will depend on how the relevant markets work

When will consumers bear the economic incidence of the tax?
• If the lemonade market was very competitive
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• so you were selling at your marginal cost = $0.20
you would not be able to pass the tax on to consumers, because if you increased price consumers would switch to a different lemonade stand
• In contrast, if you were a monopolist lemonade stand
• you could shift some of the burden of the tax to consumers by increasing price without losing too many consumers

When will workers bear the economic incidence of the tax?
• If you had many other job opportunities
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• then you would not be willing to work for less than $3.00
and your mother wouldn’t be able to find any one else to run the lemonade stand
• In contrast, if there were few other jobs available
• then you would probably be willing to accept a lower wage and so some of the burden of the tax would be shifted to workers

When will the owners of the firm, the shareholders (your mum), bear the economic incidence of the tax?
• If the lemonade market was competitive, and the labour market was competitive, then your mum, who is the shareholder or owner of the firm, would bear the incidence of the tax unless she could
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• move the lemonade stand to a location where there was lower corporate income tax declare that the profits made from the lemonade stand were attributable to activities in a different location where there was lower corporate tax

The market for lemonade

Tax incidence in the market for lemonade

Tax incidence with less price sensitive consumers

Tax incidence with more price sensitive consumers

Who bears the economic incidence of corporate income tax?
• Consumers
• if the impact of tax is to increase prices
• Workers
• if the impact of tax is to reduce wages
• Shareholders
• if the impact of tax is to reduce dividend or reduce capital gains
• We don’t actually know who bears the economic incidence of corporate income tax
• but our best estimates suggest that at least half, if not more, is borne by shareholders, with the rest falling on workers and consumers

Why all the recent fuss about corporate income taxes?
• Despite the long running concerns and the claims that companies do not pay enough tax
• revenues from corporate income taxes have been surprisingly buoyant
• This is because corporate taxable profits have increased as a share of GDP
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• share of activity in firms has increased profitability of firms has increased
• However, some firms pay much more corporate income tax than others
• and there is some disagreement about where they should pay tax

Current international system for taxing corporate income
• Our current system for taxing corporate profits is based on a system first established in the 1920s
• Corporate profits are taxed in the location where value is created
• This is difficult to implement in practice because of
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• the increased use of ideas and other intangible assets to create value and the increased international mobility of corporate activity

Why all the recent fuss?
• One likely important reason: economic activity increasingly arising from intangible assets
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Tangible assets include: machinery, land, buildings
Intangible assets include: patents, trademarks, brand names
• intangible assets can be exploited simultaneously in multiple locations

Why did Starbucks pay so little tax in the UK?
• (very simplified) the UK subsidiary made royalty payments to another Starbucks subsidiary in the Netherlands
• payment for use of intellectual property
• the subsidiary in the Netherlands paid tax

How much should Starbucks pay?
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The current international tax system aims to tax profits at the source where the profits arise
What is the source of Starbucks profits?
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• when I buy a cappuccino in Starbucks what am I paying for?
the machines?
the fact they ask my name and write it on the cup the music they play? that they give me the free iTunes download?
those things were “created” at headquarters in the US, not in the UK branch
• In addition, it is difficult to know what is the “market” price of these intangible assets, as they are not traded on the market

Why did Facebook pay so little tax?
• Facebook paid all of its profits out to its workers
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• presumably the Facebook owners thought it was the workers who had all the good ideas that generated profits would it have been more fair for the owners of Facebook to keep those profits instead of paying them to workers?
• Workers paid tax on these earnings
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• many will probably paid tax at 40% if the firm had kept profits it would have paid 20% if this is true then the UK got more tax receipts than if
Facebook had retained the money as corporate profits

How should we tax corporate income?
• Our current system is outdated
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Current policies are like trying to patch up a leaky boat
Taxing corporate profits in the location where value is created is not very meaningful (and so potentially unfair)
• There is considerable disagreement over how to improve matters
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• not just between consumers, workers and shareholders also between governments

Final comments
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It is difficult for governments to reach agreement on cooperation, because they have their own incentives
Governments want to:
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• lower tax in their country to attract real investment lower tax on “their” firms to generate competitive advantage when they compete abroad yet (some) also want to tax corporate revenue
• There are better ways to tax this income
• one possibility: tax profits at the destination of sales rather than the source of profits
• wouldn’t solve all the problems, but could improve things
• see Auerbach and Devereux (2012) and Devereux and Vella (2014)