Originally posted by scooterscot
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The trouble is every bilateral DTA I've seen says that the sort of storage and distribution operation Amazon runs doesn't give rise to a tax liability in the host country. You need to remember that at the moment any Scottish (or UK, French, German etc) business can sell elsewhere in Europe and have a local warehousing and distribution arrangement without having to deal with local corporation tax etc, and if you change those rules for Amazon you need to change them for everyone, and they would need to be the same in both directions, which means making it more complicated and expensive for other people to do business in Scotland and vice versa. So you're going to have a job changing that because the other party would likely object, although you would have the theoretical advantage of starting with a clean sheet as technically there wouldn't be a preexisting tax treaty to renegotiate.


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