Morrissey Central "I DON’T KNOW WHY MY MOTHER IS DEAD" (August 23, 2020)

I DON’T KNOW WHY MY MOTHER IS DEAD

“Following a stroke, her recovery was remarkable.
She had three extensive head-to-toe examinations by the NHS who could find nothing amiss.
Four days following the third all-clear examination I was told that my mother had three weeks to live.
Nine days later she had withered and died without any attempt by the NHS to save her life.
Once the NHS waves you off with paracetamol, get ready to meet your maker.
The official cause of my mother’s death was not the trendy and unquestionable “covid” - but, instead, cancer of the gallbladder … which had gone undetected by the NHS during their three thorough investigations.
How I wish to all gods that my mother had expressed no faith in the NHS.
She might still be alive today.”

Morrissey
23 August 2020.


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Media item:
 
Yes so what, how are you going to find it? The owner doesn’t have to be a director. The name doesn’t have to be Morrissey Limited. It’s easy to avoid PSC if you want to. The fact is that none of the experts here or anyone else knows if Morrissey owns a UK company, despite all the claims they do.

Lol ok .
 
Royalty withholding tax is an income tax that's taken at source.
A great point that the anonymous expert omitted.
 
Ok so the answer is that people on Morrissey Solo said so, finally.

Do you think 100% of corporate strategy is based on tax? Sounds like you’re the biggest tax avoider of them all.

I am pretty sure I didn't say "100% of corporate strategy is based on tax".

But it is a key component for anyone wanting to avoid paying tax. Every company in the world has accountants on board and one of their objects would be tax efficiency. Not necessarily 100% of their work but definitely up there. No company will want to pay more tax than they need to in the company they exist in.

Whether it is moral to deliberately set up structures in countries to avoid paying any tax is a different question but what I have been talking about is what is legally acceptable.

I actually pay more income tax than I need to in the UK because I think fairness comes into it. But that isn't what this has been about.

And this has nothing to do with what people state on here. It is based on facts. Whether you accept that or not I don't really care about and this hasn't been about stating Morrissey is being illegal or a cheat and I have stated that isn't the case several times but people's auto defence of him makes them feel like he is being accused of doing something illegal and I have never said that and I refuse to lecture people on morals, that is up to individuals to have views on that themselves and it is emotive.

When people stated on here alleged facts about his tax situation in the UK that are false it is a question I responded to. You can't please everyone all the time and people who are not familiar with how corporate structures work around taxation probably still can't accept how in reality it works but this is exactly how large multinationals avoid paying large amounts of UK tax. They are paying tax in countries that are not the UK so under dual tax treaties they are not obliged to pay again in the UK. They just end up choosing to pay the tax in countries where it is cheaper for them and who doesn't want a cheaper deal? I have mixed feelings about the morality of these things but as I say that isnt what is being discussed and I dont really want to get into the moral side of it. I was just explaining how and why things work this way. Take it or leave it.
 
I am pretty sure I didn't say "100% of corporate strategy is based on tax".

But it is a key component for anyone wanting to avoid paying tax. Every company in the world has accountants on board and one of their objects would be tax efficiency. Not necessarily 100% of their work but definitely up there. No company will want to pay more tax than they need to in the company they exist in.

Whether it is moral to deliberately set up structures in countries to avoid paying any tax is a different question but what I have been talking about is what is legally acceptable.

I actually pay more income tax than I need to in the UK because I think fairness comes into it. But that isn't what this has been about.

And this has nothing to do with what people state on here. It is based on facts. Whether you accept that or not I don't really care about and this hasn't been about stating Morrissey is being illegal or a cheat and I have stated that isn't the case several times but people's auto defence of him makes them feel like he is being accused of doing something illegal and I have never said that and I refuse to lecture people on morals, that is up to individuals to have views on that themselves and it is emotive.

When people stated on here alleged facts about his tax situation in the UK that are false it is a question I responded to. You can't please everyone all the time and people who are not familiar with how corporate structures work around taxation probably still can't accept how in reality it works but this is exactly how large multinationals avoid paying large amounts of UK tax. They are paying tax in countries that are not the UK so under dual tax treaties they are not obliged to pay again in the UK. They just end up choosing to pay the tax in countries where it is cheaper for them and who doesn't want a cheaper deal? I have mixed feelings about the morality of these things but as I say that isnt what is being discussed and I dont really want to get into the moral side of it. I was just explaining how and why things work this way. Take it or leave it.
Happy to leave it. No, not every company in the world has accountants on board - far from it. They are not all desperately structuring to mitigate tax exposure either.

I assume you want someone to say ‘wow you’re an expert on corporate structures - you are a god’. Not so much.
 
 
He doesn't get the payments. The payments are made to a company which is outside of the UK. He then is paid a salary and dividends from that company in the country it exists in. There is no income tax liability for him in the UK and because he also has no corporate connection in the UK there is no company that he is a director of that is obliged to pay corporation tax here either. The record company is liable to tax on its sales but that isn't Morrissey's income tax.

Incorrect. The key question is : where is he resident for tax purposes? The UK? The USA? Switzerland? If he is resident in the UK then he pays UK income tax on his worldwide income. If he is resident elsewhere in the world, then that is where he pays his tax.
 
Yes so what, how are you going to find it? The owner doesn’t have to be a director. The name doesn’t have to be Morrissey Limited. It’s easy to avoid PSC if you want to. The fact is that none of the experts here or anyone else knows if Morrissey owns a UK company, despite all the claims they do.

Not really any more.

It isn't possible for an owner of a company to not be registered at companies house and hasn't been possible since around 2015 under changes brought in by the LibDem/Tory government by Vince Cable.

It is a requirement now that all owners of all companies are registered with companies house on the beneficial ownership register which is a public register.

The aim of this change was to bring about complete transparency as to who actually owns companies in attempts to reduce tax evasion, organised crime connected financial structures and terrorism.

It also at the same time ban bearer shares which were shares issued by a UK company to an owner.

If Morrissey was an owner of a company in the UK he would be on that register. There is no way around that.

There are silent partnerships but they are generally used by people who are directors of companies to have a silent investor but they have no control over the company and can stand to lose money.

For Morrissey to be a part of a corporate structure but have no significant control would be high risk for his money and quiet frankly bonkers.

And as I have explained previously you need to ask what would be the point to having a UK based company when his permanent address isn't based in the UK. It is possible for a non resident to open a company in the uk but there would be no reason to do so in this instance. It would achieve no purpose in this structure.

I'm not sure why you are so against the idea that he may not have a tax or financial presence in the UK.
 
A great point that the anonymous expert omitted.

I already answered this.

Came in last year.

It isn't applicable when the money goes to a company in a country with a dual tax treaty and US, Ireland, Switzerland have one. The treaty assumes that any tax due is paid to the country where the company is according to the tax rules of that country and it was to try to get some tax from digital media because without it the UK only gets a tiny bit of VAT.

So doesn't apply. Governments keep bringing these things in to try to deal with the digital age but in reality they don't really work too well when companies are protected from it re Dual Tax Treaties.
 
You've been googling again.

So The Royalty Withholding tax was introduced only last year and is the UK government's response to try to get some money from new streaming technologies.

Until April last year there was no such tax and the UK government had no means within tax legislation to get some tax from the streaming companies. Prior to this when people bought or streamed music or film content through a streaming company the profit from that was not present in the UK. The money was taken from the customer outside the UK such as with Apple, Netflix. Amazon etc etc. There was no legal physical sale within the UK. The purchase was made on a system that was not considered to physically present in the UK so the only income the HMRC could get from such purchases and rentals etc was a bit of VAT/sales tax.

This new law started in April 2019 and effectively states that although digital content it is to be considered a sale within the UK so the UK takes 20% of the sale and only 20%.

However the key thing with this new tax is that it does not apply when the money is going to a company in a country that has a Dual Taxation Agreement with the UK because that agreement accepts that the destination company will be paying tax in its home country and therefore is exempt from the new tax. Switzerland has such an agreement as does the USA, Ireland and many other countries.

So again the money from these sales will get paid by the seller, such as the streaming company to the offshore company without the withholding tax being required or taken. It is assumed that the officials of the target company will be paying its tax as required in the country it resides in, not in the UK. People are not that dumb. Again structures and companies are in place to keep an efficient tax system.

It's not new.

They brought in additional legislation to cover digital.
 
Not really any more.

It isn't possible for an owner of a company to not be registered at companies house and hasn't been possible since around 2015 under changes brought in by the LibDem/Tory government by Vince Cable.

It is a requirement now that all owners of all companies are registered with companies house on the beneficial ownership register which is a public register.

The aim of this change was to bring about complete transparency as to who actually owns companies in attempts to reduce tax evasion, organised crime connected financial structures and terrorism.

It also at the same time ban bearer shares which were shares issued by a UK company to an owner.

If Morrissey was an owner of a company in the UK he would be on that register. There is no way around that.

There are silent partnerships but they are generally used by people who are directors of companies to have a silent investor but they have no control over the company and can stand to lose money.

For Morrissey to be a part of a corporate structure but have no significant control would be high risk for his money and quiet frankly bonkers.

And as I have explained previously you need to ask what would be the point to having a UK based company when his permanent address isn't based in the UK. It is possible for a non resident to open a company in the uk but there would be no reason to do so in this instance. It would achieve no purpose in this structure.

I'm not sure why you are so against the idea that he may not have a tax or financial presence in the UK.

He could be a sole trader & not on companies house.
 
Happy to leave it. No, not every company in the world has accountants on board - far from it. They are not all desperately structuring to mitigate tax exposure either.

I assume you want someone to say ‘wow you’re an expert on corporate structures - you are a god’. Not so much.

Not at all. Why would I want someone to say I'm a god.

I have just provided knowledge, if you think that is me trying to be a god then that would be weird. And if you don't like the knowledge then fine but it has nothing to do with a super power.

Yes I am pretty sure there are many simple companies who dont have or need accountants and they can do their own accounts but you would be amazed at the number of companies that do employ the services of an accountant. Most people don't want the hassle of keeping up to date with all the paperwork and returns etc when what they want to do is get on with what they set the company up for.

Any company that has a more complex structure will have an accountancy service of some kind and will likely have a lawyer involved somewhere along the line. It isn't about "desperately structuring to mitigate tax exposure". it has more to do with making a company tax efficient and if you would be shocked to discover people do consider ways to reduce their tax liability then... well.... welcome to the real world of corporate finance.

Now you suggest for some reason he closed his old visible companies that were used for publishing etc down and set up some kind of hidden company in the UK. And you think that would be normal but having a company outside of the UK when he emigrated would be suspicious and unlikely. Strange
 
Not really any more.

It isn't possible for an owner of a company to not be registered at companies house and hasn't been possible since around 2015 under changes brought in by the LibDem/Tory government by Vince Cable.

It is a requirement now that all owners of all companies are registered with companies house on the beneficial ownership register which is a public register.

The aim of this change was to bring about complete transparency as to who actually owns companies in attempts to reduce tax evasion, organised crime connected financial structures and terrorism.

It also at the same time ban bearer shares which were shares issued by a UK company to an owner.

If Morrissey was an owner of a company in the UK he would be on that register. There is no way around that.

There are silent partnerships but they are generally used by people who are directors of companies to have a silent investor but they have no control over the company and can stand to lose money.

For Morrissey to be a part of a corporate structure but have no significant control would be high risk for his money and quiet frankly bonkers.

And as I have explained previously you need to ask what would be the point to having a UK based company when his permanent address isn't based in the UK. It is possible for a non resident to open a company in the uk but there would be no reason to do so in this instance. It would achieve no purpose in this structure.

I'm not sure why you are so against the idea that he may not have a tax or financial presence in the UK.
The problem is you’re wrong again. There are loads of loopholes in PSC rules and if you were as well informed as you try to make out that would be painfully obvious. Oh wait a minute - vince cable cracked down on it did he? ‘The beneficial ownership register’? That doesn’t exist. Are you just googling all this crap? You might be referring to PSC disclosure. Which you can’t search en masse. And which is easy to get round legally. Which you would know if you were a hot shot tax and corporate structuring expert , which you’re not, so log off and piss off. Anonymous prick.
 
He could be a sole trader & not on companies house.

I have no idea why a thread on Morrissey's mums death has turned into a discussion about tax etc, the only comment I will make on this Nerak is that if he was a sole trader and went bust, all of his assets would be at risk whereas if he was registered as a Ltd company they wouldn't.
 
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Not at all. Why would I want someone to say I'm a god.

I have just provided knowledge, if you think that is me trying to be a god then that would be weird. And if you don't like the knowledge then fine but it has nothing to do with a super power.

Yes I am pretty sure there are many simple companies who dont have or need accountants and they can do their own accounts but you would be amazed at the number of companies that do employ the services of an accountant. Most people don't want the hassle of keeping up to date with all the paperwork and returns etc when what they want to do is get on with what they set the company up for.

Any company that has a more complex structure will have an accountancy service of some kind and will likely have a lawyer involved somewhere along the line. It isn't about "desperately structuring to mitigate tax exposure". it has more to do with making a company tax efficient and if you would be shocked to discover people do consider ways to reduce their tax liability then... well.... welcome to the real world of corporate finance.

Now you suggest for some reason he closed his old visible companies that were used for publishing etc down and set up some kind of hidden company in the UK. And you think that would be normal but having a company outside of the UK when he emigrated would be suspicious and unlikely. Strange
Lol, now it’s the world of ‘corporate finance’ which is something different altogether. Is this an automated google -bot ffs
 
Incorrect. The key question is : where is he resident for tax purposes? The UK? The USA? Switzerland? If he is resident in the UK then he pays UK income tax on his worldwide income. If he is resident elsewhere in the world, then that is where he pays his tax.

That is exactly what I have been saying for hours.

He isn't resident for tax purposes in the UK. His income as with all artists will be to a company structure. He needs to do this because he isnt an employee of the record company or the promotions company so the income goes to that company from wherever and then the money is owned by the company not by him personally.

Your point re worldwide income isnt quite correct though. He can be resident for tax purposes in more than one country at a time and the tax owed in each country is per the rules of that specific country but with each of those countries having Dual Tax Treaties with the UK he would in that instance not be obliged to pay tax on an income received in Switzerland in the UK because that would go against the DT agreement. But not relevant in this instance. Yes if someone was tax resident only in the UK and had income generated globally then yes the whole tax on that global income would be paid in the UK. I am tax resident in 3 countries.
 
I have no idea why a thread on Morrissey's mums death has turned into a discussion about tax etc, the only comment I will make on this Nerak is that if he was a sole trader and went bust, all of his assets would be at risk whereas if he was registered as a Ltd company they wouldn't.

He would also pay more tax as a sole trader. Perhaps he is happy to do that....
 
It's not new.

They brought in additional legislation to cover digital.

You are right that it was not new legislation but what was brought in on April 2019 was a new withhold tax related to a much wider scope. Prior to 2019 the withhold had a very narrow scope and didn't cover an awful lot and was not bringing them money as they wanted it to.

The whole point of the new tax was as you say digital formats which is where the majority of sales come from these days and have done for a long time. Non digital again as I have gone through is dealt with by the record company and isnt directly related to income tax.

But the key point which you still miss is that it still doesn't apply, and has never done, when the company is based in a country that has a Dual Tax agreement.

It's real objective is to prevent the movement of royalties to countries with which the UK doesn't have a Dual Tax Agreement and many of those are countries have very low taxation so it is at attempt to stop tax evasion.

An example of this is when thinking about someone who buys something off iTunes in the UK. The royalty is received by Apple currently in Ireland. Ireland and the UK have a DTA so the UK can not withhold royalty tax. However what they are targeting is instances where if that royalty in Ireland was then forward paid to a company in say Brazil. Brazil does not have a DTA with the UK so it is then argued by the HMRC to be a payment direct to Brazil and then they will withhold the royalty tax.

In the scenario we are talking about if Apple transferred the royalty to a company which owns the copyright for the purchase to say Switzerland or Ireland then because they have a DTA the HMRC would not withhold the royalty tax. It would then be up to the company to pay the tax according to the tax rules in that country, not the rules of the UK and that generally will result in a lower tax liability and it wouldn't come into the UK.

This is the long running grievance people have with Apple for example. They make huge amounts of money on iTunes and app store sales and streaming fees but they don't go into a UK company account. They go into an Apple Irish account and the Irish government gives Apple a preferential tax benefit where they save huge amounts of money annually on their tax bill. But because there is a DTA set up the UK can not withhold tax.
 
I have no idea why a thread on Morrissey's mums death has turned into a discussion about tax etc, the only comment I will make on this Nerak is that if he was a sole trader and went bust, his assets would be at risk whereas if he was registered as a Ltd company they wouldn't.

I can't remember either!

He could have different things for different income streams - no one seems to know.
 
You are right that it was not new legislation but what was brought in on April 2019 was a new withhold tax related to a much wider scope. Prior to 2019 the withhold had a very narrow scope and didn't cover an awful lot and was not bringing them money as they wanted it to.

The whole point of the new tax was as you say digital formats which is where the majority of sales come from these days and have done for a long time. Non digital again as I have gone through is dealt with by the record company and isnt directly related to income tax.

But the key point which you still miss is that it still doesn't apply, and has never done, when the company is based in a country that has a Dual Tax agreement.

It's real objective is to prevent the movement of royalties to countries with which the UK doesn't have a Dual Tax Agreement and many of those are countries have very low taxation so it is at attempt to stop tax evasion.

An example of this is when thinking about someone who buys something off iTunes in the UK. The royalty is received by Apple currently in Ireland. Ireland and the UK have a DTA so the UK can not withhold royalty tax. However what they are targeting is instances where if that royalty in Ireland was then forward paid to a company in say Brazil. Brazil does not have a DTA with the UK so it is then argued by the HMRC to be a payment direct to Brazil and then they will withhold the royalty tax.

In the scenario we are talking about if Apple transferred the royalty to a company which owns the copyright for the purchase to say Switzerland or Ireland then because they have a DTA the HMRC would not withhold the royalty tax. It would then be up to the company to pay the tax according to the tax rules in that country, not the rules of the UK and that generally will result in a lower tax liability and it wouldn't come into the UK.

This is the long running grievance people have with Apple for example. They make huge amounts of money on iTunes and app store sales and streaming fees but they don't go into a UK company account. They go into an Apple Irish account and the Irish government gives Apple a preferential tax benefit where they save huge amounts of money annually on their tax bill. But because there is a DTA set up the UK can not withhold tax.

You should have stopped at 'you are right'.
 
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