The leaked memos record that Fraser Robinson – one of Uber’s London-based executives who led the $3.5 billion investment deal with Saudi Arabia in 2016 – told a senior executive that he “should move to AMS [Amsterdam]Uber was trying to convince UK tax collectors that the company was not part-managed – and therefore taxable – in the UK. A document in the Uber archives, a trove of confidential files leaked to the Guardian, noted:[Robinson] refused to move to AMS… HMRC claims Uber’s EMEA [Europe, Middle East and Africa] profits [are] taxable in the UK because of Fraser’. Q&A
What are Uber records?
projection The Uber Files is a global investigation based on a trove of 124,000 documents leaked to the Guardian. The data consists of emails, iMessages and WhatsApp exchanges between the top executives of the Silicon Valley giant, as well as memos, presentations, notebooks, briefing documents and invoices. The leaked records cover 40 countries and span from 2013 to 2017, the period when Uber was aggressively expanding around the world. They reveal how the company broke the law, deceived police and regulators, exploited violence against drivers and secretly lobbied governments around the world. To facilitate a global public interest investigation, the Guardian shared the data with 180 journalists in 29 countries through the International Consortium of Investigative Journalists (ICIJ). The investigation was managed and led by the Guardian with the ICIJ. In a statement, Uber said: “We have not and will not condone past behavior that is clearly inconsistent with our current values. Instead, we’re asking the public to judge us based on what we’ve done in the last five years and what we’ll do in the years to come.” Thanks for your response. Robinson, who was not responsible for Uber’s tax structure, resigned from the company in 2017 after refusing to move to Uber’s international headquarters and tax base in Amsterdam. He appears to have resisted Uber’s request for family reasons, and a source said he was already considering other challenges after a successful tenure at the company. He was a valued employee and was described internally as the executive who “led some of the company’s most transformative deals,” including the investment from Saudi Arabia’s Public Investment Fund (PIF), “which at the time was the largest private placement in history ». . The revelations also raise questions about former UK chancellor George Osborne, who according to the leaked documents was a private backer of the US company’s efforts to grow its UK business as the company simultaneously positioned itself to avoid future British taxes. Osborne met with Uber founder Travis Kalanick at the World Economic Forum in Davos in January 2016 – just days after the company won a major victory in the UK when Transport for London (TfL) abandoned proposals for tighter regulations on private rental vehicles. George Osborne in Davos in 2016. Photo: Ruben Sprich/Reuters In a leaked email titled ‘Davos comments’ sent after the conference, Uber’s chief lobbyist Mark MacGann said: ‘George Osborne is a strong supporter. He liked to think he was responsible for the positive outcome of the consultation for TfL.’ If the email reflected reality, the British chancellor was apparently helping an American company just as it was trying to avoid paying British taxes. A former HMRC tax inspector suggested to the Guardian: “Having senior men based in London will always carry the risk that HMRC can claim there is a U.K. [permanent establishment] of the … company or even that the … company is managed from London. “So they may have felt exposed to a serious HMRC challenge … and needed to get their house in order quickly.” Uber, which has only once recorded a global annual profit, had created a corporate structure similar to many other US companies where profits could be diverted to offshore countries – often to Amsterdam. The structures, which are legal but arguably unethical, have resulted in criticism of some major US companies that use them to avoid UK taxes, including Starbucks and Google. Under the model, passengers paid millions of pounds in fares from Uber rides in the UK directly to a Dutch-based payment processor. Uber could then argue that profits from those rides should be taxed offshore – even though the transactions took place physically in the UK – unless HMRC could prove the global company had a UK corporate presence. Instead, the UK taxi app company received most of its revenue from a sister company in Amsterdam, which paid the London company for “marketing services” – which resulted in £59.5m in revenue and £54.9m £ million costs in 2017, according to accounts filed at Companies House. A spokesman for Osborne said: “While the government inherited from its predecessors a tax code that meant tech companies paid little tax, it was George Osborne as chancellor who – with Germany – launched international OECD negotiations to change that this, a process that led to the widely welcomed global agreement last year.” Uber said: “Uber is committed to complying with tax laws and regulations wherever we operate, including the UK and the Netherlands.”
