Posts by Pellinor

Facebook pays, er, nope, gets £11m credit from UK taxman HMRC...

Speaking as a chartered tax advisor, the article is slightly misleading.

From the accounts, it looks as though Facebook has £4m to pay this year. It hasn't earnt a credit at all.

What it has done is issue a shedload of RSUs, which will in theory give it a big deduction (£70m or so) when they vest, assuming the stock price stays where it is. That is, they'll get a corporation tax credit, if and when their employees get taxed on the RSUs.

£70m-worth of RSUs would give Facebook an NI liability of around £10m, plus the income tax and employees' NI would be another £30m or so.

Basically, Facebook is not paying tax in the UK because it's giving away all its profit (and more) to its employees. The Treasury does very nicely out of this, and Facebook still ends up paying a lot of tax (it's just a different tax...).

UK.gov could reopen Google's £130m HMRC tax deal, says Parliament

Re: Pour encourager les autres

Mike Shepherd - you are entirely correct: if the accounting entries aren't reasonable compared to an arm's length situation then they get over-ridden by the market rate. In fact the company is obliged to do so if it feels that the accounting rate is wrong. The problem is establishing whether the charges are reasonable, and if not what they should be.

This did apply in this case: Google UK used one rate, which it claimed was reasonable, for the amount it billed Google Ireland; HMRC said it should have been charging more; Google conceded the point and paid tax as if it had charged more.

The problem is that this didn't address what some people consider to be the central problem, which is that Google's UK income is from providing marketing support to Google Ireland when the latter sells to UK customers. There is a school of thought saying that the sales are made in the UK, not in Ireland, and so Google's UK income should in fact include all those sales. HMRC looked at this question, and concluded that the sales are made in Ireland. Which is not entirely surprising, given that the rules around this area are pretty clear and well understood so it would be strange if Google had got things wrongway.

The report just shows that the PAC fundamentally misunderstands the relevant law, how companies operate, and how tax enquiries work.

A few examples:

- The £130k actually collected by HMRC is compared to amounts asked for by other countries, and found wanting. But amounts which have been asked for are always going to be overstatements. It's like saying someone undersold their house, if they sold for £200k and a similar one was on the market for £300k, as clearly theirs would be worth £300k too. But the £300k is an aspiration, and there is no guarantee that it is at all realistic.

- The report refers to the previous PAC report, which found that "to avoid UK corporation tax Google relied on “the deeply unconvincing argument that its sales to UK clients take place in Ireland, despite clear evidence that the vast majority of sales activity takes places in the UK”". The "clear evidence" is that a Google employee told the PAC that he thought there was sales activity going on. It seems extremely unlikely that this person (not a tax person) understood the definition of "sales activity" for tax purposes, which has a lot of nuanced precedent about it; so I'm not at all sure why the PAC thinks that their impression should be more reliable than HMRC's.

- On the issue of transparency vs confidentiality, they seem to miss the point completely when they say "We have not, for example, seen any evidence to prove that confidentiality results in more tax being raised than would otherwise be the case". That's not why you keep things confidential!

Investors furious that Amazon only made $482m last quarter

Re: It's a tax dodge and always has been

It's not a very *good* tax dodge, though, is it?

If we make a $million in profit we'll pay $350k in tax and only have $650k left!

Why don't we *not* make a profit? That way we get to keep the *whole* of our nothing at all! We've shafted the taxman, and it's only cost us $650k... oh, wait...

Facebook's UK wing paid just £4k in corporation tax last year

What's happened here seems to be due to Facebook's employee share scheme (which I believe is actually restricted stock units, but the principles are the same).

I don't know any details of Facebook's scheme, but with RSUs generally the employer says to employees that if you meet performance criteria you may get a certain number of shares. At the end of the vesting period you get issued a proportion of these (depending on how well you did), which will be worth a fair amount (especially if the share price has been increasing, which Facebook's has been).

Although there's no direct cost to the company (all they do is issue shares), for accounting purposes it gets treated as if the company has paid you a bonus. For tax purposes, the company gets a tax deduction equal to the current value of the shares you've received; you get taxed on the same amount; and there's NI on it too.

So here we seem to have have Facebook with a loss of £28.5m, after an RSU charge of £35m, and so underlying profits of £6.5m. There is however no corporation tax on these profits as the £35m tax deduction wipes out the taxable profits.

If the RSUs weren't issued, there would be corporation tax of around £1.3m payable by Facebook,

As they were, there is income tax and NI of around £20m or more, payable by the employees and the employer. There's also a big tax loss in Facebook UK, which will save maybe £5.7m of tax in the future.

Overall, by shifting profits from the company to the employees, Facebook has increased the Treasury's tax take by £13m or more. And, incidentally, put the rest of the value in the hands of UK employees, rather than the company's shareholders generally.

Join Uber in a tale of rent seeking and employment law

Re: Employement status is more complex than that

"that's easily fixed: if you don't get sick pay, holiday pay, etc., you are not an employee in status and therefore not in tax."

The Office of Tax Simplification has been looking at this, and one of the themes they've drawn out in their most recent report on the subject (I know I raised it when talking to them, and I suspect a lot of other people did too) is that getting the tax and employment law aligned would make life an awful lot simpler all round.

The problem is that businesses and the courts regard employment as a privileged status which should only be granted to those who merit it, whereas HMRC regard self-employment as the privilege and would rather that employment is treated as the default option.

So as long as the review is being done by the Treasury and HMRC, so they get to draw the line, we're not going to get a sensible synthesis of tax and employment law :-(

Re: Employment status is more complex than that

"As far as I'm aware, you do have to accept the jobs that are assigned to you while logged on, though you can log out at any time, and you do have to follow the route on their sat-nav."

That's interesting, and pushes the analysis more towards employment. Being able to log out at will does seem to limit the mutuality of obligation, though, so I'm not sure it would be at all conclusive.

Having to follow Uber's sat-nav route could bring the driver within "supervision, direction, or control", though that's more important where there's an intermediary than where a driver is engaging directly.

Re: Employement status is more complex than that

Yes, but that was a) in California, which has a different view of the world from most people's, and b) a situation where it's worthwhile being employed rather than self-employed. In the UK it's widely accepted that it's in your interest to be self-employed if you can be.

And the tests in the US are very different from the UK ones. Some similar concepts - but in particular they have a default to employment, which (maugre HMRC's head) we don't in the UK.

Employement status is more complex than that

As noted by AC before me, you've over-simplified the self-employment position.

It is perfectly possible to be a self-employed contractor working for only one customer, it's just that it's a bit tricky. However, if we have an individual working directly with Uber, it gets a lot simpler than the situation where an intermediary gets involved. You'd have to run through all the various tests about financial risk, mutuality of obligation, provision of equipment, and so on, but I wouldn't be at all surprised if the reality of the relationship between a driver and Uber was that the driver was self-employed.

I don't know what the contract says, but if the driver doesn't have to pick any particular person up, Uber doesn't have to send any particular customers the driver's way, he has to provide his own cab and get it maintained, he has to pay for fuel, Uber can't dictate the route to be driven, and so on, then you're looking rather a long way from employment. HMRC may disagree, of course :-)

If you were to bring an intermediary in to the loop then you'd have more of an issue, as Uber being able to exercise supervision, direction or control over the driver would be enough to impose a PAYE liability, self-employment notwithstanding. I'd imagine that there's a risk of supervision there, at least. But without the intermediary you fall back to good old employment status tests.

THEY WANTED OUR WOMEN: Neanderthals lusted after modern humans

Re: Early modern

When I was at Oxford, "Modern" history started in 410 AD with the fall of Rome :-)

EU: Explain your tax affairs. Google, Amazon, Facebook: Mmm... nah

Re: Surprising

Yes, they've been before the Public Accounts Committee a couple of times, where they were roundly told they were in the wrong and should be ashamed of themselves, and anything they said in their defence was either interrupted, dismissed, or simply ignored.

I wonder why they won't go along to another similar session?

The rare metals debate: Only trace elements of sanity found

On the Hafnium point: is this like saying (taking your fridge analogy):

- to make decent fried bread we need bacon fat

- bacon fat gets left in the pan when we fry bacon

However:

- we have lots of packets marked "bacon" in the fridge

- there are none marked "bacon fat"

- so we cannot have any fried bread for breakfast :-(

Why Joe Hockey's Oz tax proposals only get five out of 10

One thing I wonder about with the Article 5 permanent establishment rules is whether Amazon warehouses are simply acting as storage or for delivery.

Yes, they do some storage: great wodges of stock are pile up there. They also serve as the starting point for deliveries. But in between there is a load of activity around making up the orders, packing them, and labeling them. Is that within the exemption? I'm not entirely sure.

If I could be bothered I'd go back and have a look at those industrial buildings allowances cases about whether breaking bulk and packaging are "processes" for IBAs purposes. If they are, then they'd fall within the exemption if the processing were to be done by another enterprise, but not necessarily if done by the owner of the goods.

Actually, having a look at Lexis Nexis (other providers of legal information are available) I note that last year Next Distribution were arguing that there was a process, but the First Tier Tribunal found that what was done was not uniform enough for there to be a "process" for IBA purposes (which seems a bit unfair, but hey ho). So if there is enough bespoke stuff being done by Next to elevate the work above a mere process, then arguably if Amazon is in a similar situation it would follow that as (in the hierarchy of work being done) picking-and-packing is more than just a process, it is also more than just storage. Which could take Amazon out of the PE exemption, and give them a hefty UK taxable presence.

Not that I know enough about the detail of any of these cases to be definitive, of course.

Re: GST/VAT Rates for International Sales

You're almost right about the sale of goods: the basic rule would be that the sale is where the seller is. However, there are special rules for "distance selling", which is a cross-border sale where the customer isn't VAT-registered. If you're over the threshold for distance selling in a jurisdiction (which is usually €35k though it can be €100k), the place of supply moves to the customer's location.

VATMOSS is designed to replicate this for digital services; the problem for small businesses is that they neglected to put in the threshold.

The voters hate Google. Heeeeyyyy... how about a 'Google Tax'?

Re: The voters hate Osborne

Income tax maxes out at 60% if you have income just above £100k, as you lose £1 of your personal allowance for every £2 above £100k. So in the £100k-£120k band, every £1 of income suffers 40p of tax and causes another 50p to pay 40% tax, giving a total tax bill of 60p - 60% effective tax rate.

You can also get some effective tax rates well above 45% in the £50-60k band where the High Income Child Benefit Charge applies, though the ETR there varies depending on the benefit you're losing. It can go above 60% if you have a lot of children.

For someone on £120k, the effective tax rate including employee's NI is 62%. If you include employer's NI, then the effective tax rate is more like 67%. Paying an employee £100 of gross salary means £60 in income tax, £2 in primary NI, and £13.80 in secondary NI - so out of the £113.80 cost to the company, £75.80 goes to the Treasury.

I suspect that cash will be raised in the short term, though it's possible that much of it will end up being refunded. As the Treasury uses cash accounting, that will look good for now.

There are a number of possible challenges to the DPT but, regardless of their technical merits, as Benedict-Hope has pointed out this sort of challenge takes time - and the proposals would require the tax to be paid up front. Different firms take different attitudes to this sort of thing, but I'd be surprised if they withhold cash that is demanded under what is at that point statute law.

As for the situations it addresses not being corporation tax avoidance: that is fairly simply dealt with, as the DPT isn't looking at avoidance of corporation tax . It's a separate tax from corporation tax (though I'm fairly sure the corporation tax bods at the large firms will be looking at it), so there's no particular requirement to import CT concepts like the correct attribution of profits to a permanent establishment into it. It's looking at situations that might reasonably be considered to be corporation tax avoidance if you were to apply different rules (like assuming that certain costs are inflated and discounting them by 30%: this is not something you can do for CT purposes, you have to work out an arm's-length position).

I'm not familiar enough with EU law on state aid to make much informed comment on that front, but it does strike me that there are a lot of areas where SMEs have been treated more favourably than large companies without contravening the rules - transfer pricing exemptions, R&D, Senior Accounting Officer, and so on. So I'm unsure as to how strong that sort of argument is.

Neither am I all that familiar with the details of the EU treaty, but I'm also not sure that the principle that any EU company can sell across the EU is contravened either. The UK can levy what taxes it likes on companies, so long as it does so even-handedly - and DPT applies to UK companies as well as non-UK ones. You can't levy new turnover taxes, but I'm not aware of any other restrictions that would kill this off.

I don't like this tax - it's an extra layer to paper over perceived holes in the underlying tax law, and I'd rather see those perceived holes dealt with (partly by fixing holes, partly by fixing perceptions). But I do think it could potentially raise cash.

HAPPY 20th Birthday MICROSOFT BOB

Re: Comic Sans

I like Comic Sans. When I see someone use it, it tells me that the author is wanting to be friendly, informal and comfortable; and isn't so familiar with the sibboleths of design that they know it's anathema.

The latter implies that they're a perfectly ordinary likable person who cares about the message rather than the medium and just wants to on with the job in hand. These attributes are, to me, more worthy than being a snob about fonts :-)

UK.gov in pre-election 'Google tax' blitz against internet firms

Re: I call bullshit

Private Eye requires something of a pinch of salt :-) You do realise that it has its tongue firmly in its cheek, and its editorial policy appears to be essentially that anything iconoclastic is ipso facto worthy of publication, don't you?

There is nothing about the diverted profits tax that is good for a large business. At the very least it's another bit of admin to fill in, even if they can argue that there's nothing to pay (and the rules are stacked against them: there's a built-in assumption that royalties paid are over the odds, for example, even if they're OK under transfer pricing rules). At worst it's a great chunk of tax to pay that they'll never see again. Somewhere in the middle is an extended argument with HMRC costing a lot of legal and accounting fees. None of those is a good outcome in any way - even if they come out of it with a nil assessment, they'll get adverse publicity for being dodgy enough to potentially be caught and even dodgier for sliding out of it.

If HMRC were working for Big Business, the DPT would never have been mooted.

Re: I call bullshit

If you're "small fry" and don't self-report, you're fine: the whole point is that small companies are completely exempt from the tax.

In my experience, companies smaller than £250m don't have elaborate structures anyway. Well some of the PE ones do, but that's to make sure debt is subordinated properly rather than to muck about seriously with the tax position.

Re: I call bullshit

The legislation works by having the company say what profits they think could be seen as being at risk of having been diverted, then HMRC assess an amount and demand the tax on it.

The company then has to pay the tax first and argue about it later. It's very much backwards from normal self-assessment, where HMRC have to show that your self-assessment was wrong. In many ways, it's like an accelerated payment notice being issued right from the word go.

So if you "call Osborne's bluff and file a piece of paper with the grand total of '£0.00'", HMRC can call your bluff and reply with a piece of paper saying "25% of £20bn is £5bn, payment in 30 days please".

Re: I call bullshit

If they don't, then HMRC can have a crack at them for not self-reporting and can apply higher penalties.

The initial report is simply that they might have some profits caught by the new tax, which is pretty hard to deny if you fit the fact pattern Then they have to give an initial estimate of what the amount is, which HMRC can then dispute.

I'm pretty sure HMRC will have a list with at least a few names on it that they're expecting reports from. They may be short on resources, so probably can't fight their corner as well as perhaps they should be able to (I speak as a taxpayer here, not as a tax advisor ;-) ), but they're not entirely stupid.

Re: Check it out

I'm fairly sure no-one from industry would have come up with this tax, it's a complete outlier from everything else and kind of breaks the normal principles of international tax. I also doubt anyone from the major accountancy firms did, for the same reason. It looks to me to be a political thing the Treasury were told to make work so it could be stuck in the Finance Bill. Tax bods would have been more likely worked within existing transfer pricing rules: maybe tightening up the definition of permanent establishment to bring profits into the UK.

Re: 25% of nothing is still nothing

The profit in the UK is irrelevant for DPT: the taxable profit is the amount that's deemed could have arisen if a different structure had been adopted. It'll take forever to agree any amounts, but I'm fairly sure some amounts will end up being paid. How big they'll be is anyone's guess.

The tax is on Google UK, taxing the profits that could have been made had Google structured things differently.

The idea is that Google can quite happily make actual profits in Ireland, but the UK will simply deem it to have made profits in the UK for purposes of this tax (even though not for corporation tax).

Speaking as a tax advisor, this works in theory: the problem is going to be working out what the deemed profits should be. I'm glad all my clients are too small for me to have to get involved :-)

Inside GOV.UK: 'Chaos' and 'nightmare' as trendy Cabinet Office wrecked govt websites

Re: Yep - it's terrible

Exactly my experience, as a tax advisor. Luckily I have all the paid-for reference services as well as the old free HMRC ones, but it was nice to be able to see what HMRC think about things too.

The problem with the tax pages is that they've been written to be used by someone with simple tax affairs who doesn't know much about them - lowest common denominator. Anyone with complex affairs, or who wants the legislative back-up, or who simply knows what they're talking about and needs a bit more detail, just isn't considered.

Gov.uk looks like someone designed templates - a few headings, and no more than 100 words per page - and then told people to fit the information into them. Procrustean - form driving function :-(

First HSBC, now the ENTIRE PUBLIC SECTOR dodges tax

Re: Two things

VAT is normally only recoverable by an organization which is in business (there are exceptions, of course).

Government departments are not normally in business (there are exceptions, of course).

Therefore government departments cannot normally recover VAT on their purchases (there are exceptions, of course).

All VAT rules have exceptions (except those that don't). All exceptions have exemptions from them (even the ones that don't). It's all very recursive :-)

As a tax advisor, I say 20% on everything and damn the torpedoes. Then I wouldn't have to do any VAT work and could do something more exciting, like capital allowance claims :-)

EU VAT law could kill thousands of online businesses

Speaking as a tax advisor, there are two relatively simple ways through this:

1) Make your non-UK sales through a partner that will sort out the VAT for you. I understand that Google are doing this for app sales, and other big (and some smaller) players do too. The problem is of course that you end up paying a slice of your income to the partner

2) Register for VAT, making it clear that your UK turnover is below the threshold, and then file your VAT and MOSS returns. The forms are relatively simple (OK I'm a professional, but they really aren't that hard), and you don't need to do this until you've made your first non-UK EU sale.

For many businesses, the rules won't apply. A couple of non-obvious exceptions:

- If you sell say .pdf knitting patterns, then you're not caught if you manually email them out - only if the download is automatic. For many small hobby businesses this may be happening anyway.

- If you provide on-line training videos, you're caught; if you provide on-line training videos plus live support, you're not. A minor change to what you actually do might get you out of the regime.

On enforcement: I understand that, although the MOSS return is administered by HMRC on behalf of the other EU governments, any enforcement action has to be undertaken by the government concerned. Minor infractions may therefore not be chased up terribly quickly.

If the authorities had any sense they'd agree a mutual procedure whereby say HMRC would look at MOSS returns while checking UK VAT returns, but that isn't in place at the moment.

HP, Microsoft prove it again: Big Business doesn't create jobs

Parkinson makes several good points, especially if you also read The Law and the Profits. The eponymous Law is only one of them - his analyses of injelititis, the function and functioning of a committee, and why the cost of biscuits is controlled more tightly than the cost of a nuclear power station, for example, are useful guidance almost every day.

That stirring LOHAN motto: Anyone know a native Latin speaker?

"Quid agit puga agere?"?

Possibly with an "ipsum" in there, but I think it scans better without.

"Lorem Ipsum dolor sit amet"?

Or, from the same artist (abridged):

"ut labore et dolore quaerat voluptatem" ("From labour and pain he seeks pleasure" - I think...)

Re: to the pub

"Per taberna ad astra"?

Report: Danish government hits Microsoft with $1bn tax bill

Re: Taxes?

Oh, sorry, I forgot: you're ignoring anything that isn't in the UK, because the rest of the world doesn't exist and wouldn't have any right to impose taxes if it did; and anything that isn't paid in cash, because all billion-pound firms run purely on cash.

Re: Taxes?

No UK tax? They have a total tax charge of £410m, which makes their effective tax rate near 30%, against a UK headline rate of 24.5%.

Yup, that looks like avoidance to me.

US taxman joins UK politicoes on hunt for Amazon cash

Re: Groan...

Your recommendations are pretty much how the system works already.

I'm not sure what you mean about VAT "trading" options - very little about VAT is optional. The VAT paid by a company is a slice of the value added, which is determined by what you receive from a third party for your supplies less what you paid third parties to do it. No "perceived" about it. It happens at all stages of the cycle, too. And most of the time you have things like staff costs with no VAT to recover, so your effective rate of VAT on the value you add is much higher than 20%.

Mr Bloggs can negotiate with HMRC about taxes just as much as any company can. Nearly every negotiation with HMRC that I've been involved in is an examination of what actually happened: the ones about how the tax rules should apply to the transactions are relatively rare. The reason companies negotiate more than individuals is that they do more stuff, so there's more subject matter to discuss. Tax deduction at source makes most individuals' tax affairs very clear and simple compared to those of companies.

By dividend exemption, I presume you're referring to lower rates of tax on dividends when received by individuals. Those just compensate for the fact that tax is levied twice on the same profits: once in the company, and again on the dividend. Until a few years ago the end result was pretty balanced either way; now with lower corporation tax rates dividends are usually better, but not always.

Loans are very hard to exploit, especially for individuals - ever heard of s455 tax? It's practically a penalty system.

Rule 1 of fixing a system: find out how it works now. You might be surprised.

You're right that simplification does make things fairer, but you can't take it too far or you end up making them unfair again - like your NZ trust funds. It's like a chaotic system: even where the rules are simple, they can have enormously complex consequences. The UK system is too complex now, but flat taxes bring a host of anomalies.

Re: @Pellinor Ninja Accountants

@ frank ly: I read the article, and your comment, carefully.

You say that in the total company books (by which I assume you mean the consolidated accounts) the expense would be £1, because there'd be expenses of £1.50 (presumably 50p in the US and £1 in the UK) and income of 50p. That is of course bollocks, to use the technical term, as the £1 cost in the UK would be £1 of income in the US. You've confused yourself with the 50p profit you mentioned earlier.

The article is doing this to illustrate transfer pricing, suggesting that a 100% markup might be applied even though it's a bit steep, and thus save UK tax because the UK's £1 expense is too high: if UK tax rates are higher, then saving tax on £1 in the UK is worth paying tax on £1 in the US. That's basic transfer pricing.

What you've done is suggest that transfer pricing can somehow generate expenses out of thin air: the 50p actual cost has magically turned into £1 of tax deduction. That doesn't happen: all you can do with transfer pricing is shift profits around a group. You mention other "buying expenses", but again, you can't magic them out of nothing without having some profits arise elsewhere.

Except of course HMRC is very hot on such things and would come down like a ton of bricks on anyone who tries a 100% mark-up on low-value high-volume goods, and extra fees for no good reason. It's one of their big earners: they don't bother checking every year, they just come along every five years or so, and if they're not happy with the intra-group prices they reopen earlier years and charge penalties and interest on the extra tax.

Or at least, that's what's happened in my 15 years as a Chartered Tax Advisor advising international groups on corporation tax, transfer pricing, IP, and financing. Every group I've come across has been very nervous of HMRC or the IRS coming along, and taken pains to use reasonable prices. Top end of the "reasonable" range, maybe, but with a tax provision held back in case HMRC challenge them.

Perhaps my experience is untypical - what's yours been like?

Which would make you pretty much any small service business with a few employees selling to the general public.

Gardeners, window-cleaners, IT consultancies, accountants, builders, decorators, plumbers, personal trainers.... not all that unique, really.

Nope, the UK threshold is £77k a year, not £10k. And it's only taxable supplies (which admittedly is most turnover).

And companies do suffer from VAT. You have one customer with sales of £75k, no VAT to charge, you keep £75k. I have two identical customers, sales total £150k, I have to pay £25k of that out in VAT (I can only bill £125k + VAT maximum, or they'll go to someone unregistered for the cheaper price). If the cost per customer is the same, I've lost £25k off the bottom line.

Re: Ninja Accountants

Rubbish. Income and profit are not the same thing. US parent gets income of £1, so the overall expense booked in the group of 50p. Which is, not entirely coincidentally, the actual cost of the box.

Shock, horror, Amazon gets to deduct the cost of something it bought when working out its tax bill! Stop the press!!!

Google avoids tax with ‘Double Irish Dutch Sandwich’

Re: two simple laws

Corollary 1: All eBay sellers need to set up 200 subsidiary companies.

Corollary 2: iron curtains all round.

Oh, what a fantastic idea. Having no trade at all is much better for the country than having tax-free trade.

Google may face grilling by MPs over 'immoral' tax avoidance

Not more of this rubbish.

Tax is on profit, not turnover. £6m tax suggests £25m profit, which is a margin of what, 6%? Sounds OK, given that all Google do in the UK is tout for advertising. No risk in that, so there should be no margin. All the value comes from the US: Google UK would be nothing without it.

If the MPs don't understand that, they really shouldn't be investigating anything.

Never mind the question of what the £6m is: accounts tax charge, or tax paid, or what? If it's tax paid and there's been anything in the way of capital allowances or R&D, then what do you expect?