From day 2 of the witch hunt:
CHAIR: Understand that I am a layman. I do not want to get myself in a little hole. From what you are saying, do you mean that you put a value of zero on the IP of Apple?
Mr Richardson : No. If Apple sold to Samsung, if it licensed its technology to Samsung, then, sure, we can expect that that is a legitimate transaction and we would treat it with that respect.
CHAIR: So what you are saying is that Apple Ireland and Apple Australia, in the proposal you are floating for discussion, could not be treated the way Apple is treating Samsung, which is how they treat each other now. At the moment they treat each other like they are distinct companies, distinct entities. You gave the example of Apple and Samsung. As I understand it, it is the same relationship between, say, Apple Ireland and Apple Australia.
Mr Richardson : Yes.
CHAIR: And you are saying, ‘No. They are the same company and should be treated like the same company.’
Dr Denniss : That is right.
CHAIR: That is interesting.
So effectively the Chair – law school drop-out* Senator Sam Dastyari (ALP, NSW) – is seriously considering a scheme where for tax purposes Australia should abandon the veil of incorporation in order to zero value intellectual property. That is the end game here – also reading through the Hansard I’m getting the distinct impression that our Senators can’t tell the difference between costs and profits.
* If he’d remained at Law School he would have learned about the veil of incorporation and the benefits related concepts such as limited liability have generated in the last 150 years or so.