Meanwhile, Lisa Pollack at the FT published a series of articles on Starbucks' tax affairs, looking at its apparently inconsistent statements of profit and loss, its transfer payments, and its offer to pay more tax.
Having examined the transfer payments, Pollack wrote that
This analysis was seized on by commentators hostile to corporation tax in general. But Pollack, in an otherwise informative series, has made a mistake. The profit and loss for reporting purposes is not the same as the profit and loss for corporation tax purposes. (I started on a post about this at the time: real life supervened. But Tim Worstall has today repeated the claim, so I'm going to try to put things straight.)So that’s a £33m loss less £26m of royalties less £2m of interest, which gets one to a figure of £5m… which is still a loss. Some of the mark-up from the Swiss bought coffee would have to go too to get the company near profitable in the UK.Which makes the punchline — that Starbucks has agreed to pay £10m of ‘tax’ voluntarily over the next two years — even weirder.
The £33m is Starbucks' reported UK loss for 2010-11. Pollack's point is that even if it reported results £28m better it would still be making a loss, and so (she implied) not paying corporation tax. But as the Financial Statement makes clear on page 19, some of the items contributing to the stated loss - depreciation and impairment in excess of capital allowances, and non-deductible expenses - are not allowable for corporation tax purposes. They come to about £16m apiece. Adding these back in, Starbucks' UK loss is reduced to £1m. So with the £28m in royalties and interest payments the company would have a taxable profit of about £27m.
Two additional points for clarity:
- the numbers on p19 are the affect of each item on corporation tax payable, which was 27% of the gross
- Starbucks has got past losses available to set against future profits. So it may still not need to pay corporation tax.