[...] Navigating this mishmash of regulations is no easy task. Transfer prices are very tricky. Most countries set them at "arm's length"--ie, the price an independent party would pay for a given service or product. Though the principle is a nice one, the practice is complicated, particularly because companies are increasingly service-oriented and rely more on brands, intellectual property and other hard-to-price intangibles. The issues raised by transfer pricing can thus be dauntingly philosophical. "You are dealing with fundamental questions, such as what creates value," says KPMG's Ted Keen. "And the answer is different every time." The quarrel between GlaxoSmithKline and the IRS, for instance, revolves around what made Zantac--its hugely profitable ulcer drug--so valuable. Was it the money poured into research and development in Britain, or the advertising and marketing in America? Clearly, both were factors, but deciding how much was contributed by whom, and thus how to divvy up costs, profits and taxes is hard. Of course, transfer pricing is open to manipulation. A report by America's Senate in 2001 claimed that multinationals evaded up to $45 billion in American taxes in 2000. Whatever the truth of this claim, some of the report's details were eye-catching: one firm sold toothbrushes between subsidiaries for $5,655 each. [...]
The quarrel between GlaxoSmithKline and the IRS, for instance, revolves around what made Zantac--its hugely profitable ulcer drug--so valuable. Was it the money poured into research and development in Britain, or the advertising and marketing in America? Clearly, both were factors, but deciding how much was contributed by whom, and thus how to divvy up costs, profits and taxes is hard.
Of course, transfer pricing is open to manipulation. A report by America's Senate in 2001 claimed that multinationals evaded up to $45 billion in American taxes in 2000. Whatever the truth of this claim, some of the report's details were eye-catching: one firm sold toothbrushes between subsidiaries for $5,655 each. [...]
I don't have handy revenue and profit for some companies over Europe countries, if I find the time to redo the search I'll do a diary on it.
For artists and Ireland, see wikipedia Tax Haven, the Ireland line.
Hope this helps.