Quote:
Originally Posted by murg
This is exactly the problem. Coffee Kingdom just happens to pay the Irish company the amount of its profits for the use of the name.
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That is not the problem. If that is the market worth of the use of the name then in most (probably all?) western tax jurisdictions it is an allowable deduction.
If it is not the market worth of the use of the name (and that use may also include associated management services (say as in a franchise or other rights), etc. then the problem is that the revenue in the name users jurisdiction is too lazy to challenge it and, if necessary, prove their case in court to establish a realistic valuation.