The Paradise Papers

[snowychap]

2 minutes ago, Risso said:

You'll have to explain how a point about being resident in a country and paying tax there was irrelevant in a discussion about somebody living in a country and paying tax there.

Your point was:

Quote

If you got a job in the USA for example, would you volunteer to pay tax back here?

That wasn't about where someone was resident but rather where someone worked.

It may have been implicit in your question that the country of work and country of residence was the same (as it would likely be for most people) but, as you've already established in your post, this is not the case for Hamilton (i.e. the subject of the conversation) and thus your point (about HV getting a job in the USA and paying tax in the UK) was irrelevant.

If we're to talk about the area in which you no doubt have more expertise than I do (e.g. where someone with an itinerant job such as Hamilton would pay his tax being that he does jobs of work in 17/18 countries throughout the year) then by all means play your expert card and tell me. I don't know, for example, whether he'd have to pay a proportion of some of the income he got whilst driving round Silverstone to HMRC or round Spa to the Belgians.

But that's about what he may or may not pay (and to whom) based on the decisions he has taken and not the forming of an opinion about someone when that someone might have moved their country of residence in order to minimize their tax burden.

 

[Risso]

You've pretty well answered your own point there, and apologies for the snarky post earlier, it was unnecessary.  However I still don't think Hamilton has done much wrong (other than appear on Children In Need, the bloody idiot).

You've rightly pointed out that he's an intinerant worker, and even in the rarified world of international sportsmen, Grand Prix drivers, and Hamilton in particular, are a case apart.  You've got football players like Neymar earning fortunes, but as he's living and working in France, one assumes he's getting clobbered by the French tax man to a hefty degree.  However, Hamilton is on the road for the majority of the year.  He's in a strange position tax wise where he could base himself pretty well anywhere, as long as it was within striking distance of his team and the majority of circuits, which without checking I guess are still mostly European.  So if he decided to live in France for example, and paid their very high levels of income tax, he still wouldn't be paying any in the UK.  He'd be paying the tax that France deemed necessary for residents of his earning potential, buy UK HMRC would see next to nothing.  Would he still get publicly castigated if that was the case?  He has, along with most other F1 superstars (since Nigel Mansell had a house overlooking the bay in Port Erin on the IOM), decided to live in a low [zero] tax jurisdiction, because there is just no requirement to be in the UK.  He doesn't live there, doesn't earn most of his money there, so really, why should he pay tax there.

The people that should be getting far more stick if that's what you're interested in, are the likes of Gary Lineker, Ashley Giles and all the other sports people and celebs who took part in completely artificial and aggressive schemes like the Ingenious Film Partnerships.  They live in the UK, earn most of their money in the UK, so took part in mass marketed schemes for no other reason than tax avoidance.  Have a look at this for examples, there's dozens of the buggers; https://beta.companieshouse.gov.uk/company/OC308659/officers

[snowychap]

35 minutes ago, Risso said:

You've pretty well answered your own point there, and apologies for the snarky post earlier, it was unnecessary.

Apology accepted - edit: and as I probably overstepped in response then I apologize for that.

Quote

You've rightly pointed out that he's an intinerant worker, and even in the rarified world of international sportsmen, Grand Prix drivers, and Hamilton in particular, are a case apart.  You've got football players like Neymar earning fortunes, but as he's living and working in France, one assumes he's getting clobbered by the French tax man to a hefty degree.  However, Hamilton is on the road for the majority of the year.  He's in a strange position tax wise where he could base himself pretty well anywhere, as long as it was within striking distance of his team and the majority of circuits, which without checking I guess are still mostly European.  So if he decided to live in France for example, and paid their very high levels of income tax, he still wouldn't be paying any in the UK.  He'd be paying the tax that France deemed necessary for residents of his earning potential, buy UK HMRC would see next to nothing.  Would he still get publicly castigated if that was the case?  He has, along with most other F1 superstars (since Nigel Mansell had a house overlooking the bay in Port Erin on the IOM), decided to live in a low [zero] tax jurisdiction, because there is just no requirement to be in the UK.  He doesn't live there, doesn't earn most of his money there, so really, why should he pay tax there.

I'm loath to speak for @HanoiVillan (or anyone else) but I would surmise from his comments that, had Hamilton gone to live in another country where his tax burden would be much the same (or more) aldeit to that country's treasury rather than the UK, he wouldn't receive the same level of opprobrium as his country of residence wouldn't have been chosen for the reasons of paying as little tax as possible.

We (you, HV and I for the purposes of this conversation) accept as a given where he's living and that he's paying less tax (than he would be in either of the other countries in which he lived) as a result. The differences are about whether he's chosen to live there for that purpose (I'm with HV on this and whilst you did question HV's assertion in the one post, I think you'd largely argue that this was likely, wouldn't you?) and, beyond that, what opinion we form of him for doing this. Again, I'm largely with HV on this - though I'd stop short of removing someone's citizenship (issues with making someone stateless and wotnot) or bringing out the guillotine.

As an aside, don't all US citizens have to pay US tax on all income regardlesss of where it's earned?

Edited November 20, 2017 by snowychap
To add my apology

[snowychap]

31 minutes ago, Risso said:

The people that should be getting far more stick if that's what you're interested in, are the likes of Gary Lineker, Ashley Giles and all the other sports people and celebs who took part in completely artificial and aggressive schemes like the Ingenious Film Partnerships.  They live in the UK, earn most of their money in the UK, so took part in mass marketed schemes for no other reason than tax avoidance.  Have a look at this for examples, there's dozens of the buggers; https://beta.companieshouse.gov.uk/company/OC308659/officers

I'm not sure they should necessarily be getting 'far more stick' but they should certainly getting stick. Just as The Grauniad should get stick along with the Barclay brothers at The Torygraph.

[bickster]

It's irrelevant where Lewis Hamilton lives, its where his work is based that's important

If he should be paying tax anywhere its the UK, that's where the Mercedes team is based (Brackley)

[Risso]

15 hours ago, bickster said:

It's irrelevant where Lewis Hamilton lives, its where his work is based that's important

If he should be paying tax anywhere its the UK, that's where the Mercedes team is based (Brackley)

Where he lives isn't irrelevant at all.  And because a company is based in a certain country, it doesn't follow that the employee is based there as well.  

[bickster]

48 minutes ago, Risso said:

Where he lives isn't irrelevant at all.  And because a company is based in a certain country, it doesn't follow that the employee is based there as well.  

Risso, I'm not talking in your currently legal, number-crunching world, I'm talking in my, he should pay his effing taxes like everyone else world, the world I create come the glorious day

But I also suspect Hamilton spends more time in Brackley than any other single location in the world, which would be my definition of where he works.

I suspect he only works in Monaco 1 week of every year and that Mercedes Petronas don't have a facility there that he can work from

[Risso]

23 hours ago, bickster said:

Risso, I'm not talking in your currently legal, number-crunching world, I'm talking in my, he should pay his effing taxes like everyone else world, the world I create come the glorious day

But I also suspect Hamilton spends more time in Brackley than any other single location in the world, which would be my definition of where he works.

I suspect he only works in Monaco 1 week of every year and that Mercedes Petronas don't have a facility there that he can work from

 

I'm afraid you're absolutely wrong on that score.  I play football on a Tuesday night with one of the senior technical directors at the Mercedes AMG plant in Brixworth, who are responsible for building the engines that go into the F1 cars.  I asked him last night how many times Hamilton visits either Brixworth or Brackley, to be told it was less than a handful of times a year.  The most recent time being for the mass photo at Brixworth a couple of days ago with everybody who works there.  

[bickster]

Just now, Risso said:

 

I'm afraid you're absolutely wrong on that score.  I play football on a Tuesday night with one of the senior technical directors at the Mercedes AMG plant in Brixworth, who are responsible for building the engines that go into the F1 cars.  I asked him last night how many times Hamilton visits either Brixworth or Brackley, to be told it was less than a handful of times a year.  The most recent time being for the mass photo at Brixworth a couple of days ago with everybody who works there.  

Handful + Monaco = Handful +1, Handfull is greater than 1

[Risso]

9 minutes ago, bickster said:

Handful + Monaco = Handful +1, Handfull is greater than 1

He lives in Monaco when he's not travelling around the world driving his car a bit quick.  I'm really not sure why you think this isn't the case.  As a Monaco tax resident, he will have his days in the UK and other countries, (but especially the UK) monitored very closely indeed.  Ultra High Net Worths like Hamilton have to provide proof in the form of travel documentation etc.

[bickster]

5 minutes ago, Risso said:

He lives in Monaco when he's not travelling around the world driving his car a bit quick.  I'm really not sure why you think this isn't the case.  As a Monaco tax resident, he will have his days in the UK and other countries, (but especially the UK) monitored very closely indeed.  Ultra High Net Worths like Hamilton have to provide proof in the form of travel documentation etc.

Risso, I've already said, I'm not talking about what is currently legal so why persist with that line? I'm not saying he's doing anything wrong under current rules and regs

Couldn't give a crap where he lives, he works there one week a year in one visit. Someone could live in Outer Mongolia for all I care but if his primary work site is in the UK, he should pay tax in the UK

[Risso]

8 minutes ago, bickster said:

Risso, I've already said, I'm not talking about what is currently legal so why persist with that line? I'm not saying he's doing anything wrong under current rules and regs

Couldn't give a crap where he lives, he works there one week a year in one visit. Someone could live in Outer Mongolia for all I care but if his primary work site is in the UK, he should pay tax in the UK

But his primary work site rather obviously isn't in the UK.  It's in Italy, Germany, Abu Dhabi, Australia and all of the other racing circuits around the world.  

[bickster]

31 minutes ago, Risso said:

But his primary work site rather obviously isn't in the UK.  It's in Italy, Germany, Abu Dhabi, Australia and all of the other racing circuits around the world.  

Each of which he visits once. With the exception maybe of a testing circuit, which he probably visits twice

He visits UK facilities more often than twice. UK taxpayer come the glorious day

[Risso]

11 minutes ago, bickster said:

Each of which he visits once. With the exception maybe of a testing circuit, which he probably visits twice

He visits UK facilities more often than twice. UK taxpayer come the glorious day

That would be quite easily avoided, he just wouldn’t come here at all. He does no “work” here. This visit this week was just to visit the staff at Brixworth. Was a pain in the arse with people parked up trying to get a look.

[bickster]

He'll not be racing at Silverstone then

[snowychap]

5 minutes ago, bickster said:

He'll not be racing at Silverstone then

No one will (in F1), soon.

Edited November 22, 2017 by snowychap

[markavfc40]

I think the issue here is that while Hamilton can avoid paying tax in this country why would he? he was born here, educated here, I'd imagine used the NHS and other public services, will still have friends and family here. You'd like to think he'd be more than happy to pay his taxes here.

[Risso]

19 minutes ago, markavfc40 said:

I think the issue here is that while Hamilton can avoid paying tax in this country why would he? he was born here, educated here, I'd imagine used the NHS and other public services, will still have friends and family here. You'd like to think he'd be more than happy to pay his taxes here.

While he was being educated, presumably it was his parents' taxes that were paying towards that.  I'm not sure I'd vote for a system where you had to pay taxes in a certain country for the rest of your days despite not living or working there, and thus not consuming any resources there.  

[Davkaus]

46 minutes ago, bickster said:

He'll not be racing at Silverstone then

No more often than every other F1 driver. Should they all be UK taxpayers too?

Edited November 22, 2017 by Davkaus

[TrentVilla]

 

Surely the issue with Hamilton is plane purchase?

He doesn't reside in the UK, he shouldn't be taxed in the UK. Whatever I think of him or the moral decision of people like him to be non dom they aren't doing anything wrong as such.

The plane purchase, based on what I've seen looks dodgy.