Hands-On With the World-Changing $40 Tablet

Aakash2

The Aakash2 is available for $ 40.41 (2,263 rupees), but the government of India will subsidize half the cost for schoolchildren. The tablet is conceived as a tool to help end India‘s rampant illiteracy. Aakash2 will bring school-age children connectivity and unprecidented access to books.

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The Aakash2, the second generation of the monumental, ultra-cheap tablet from Indian manufacturer DataWind, arrived in the U.S. Wednesday, with a welcome at the U.N. Headquarters in New York.

DataWind is hoping to prove to the tech and development communities that the $ 40 Aakash2 is faster than its predecessor, the original Aakash, which was much-criticized for its glacial processor.

[More from Mashable: The Top 5 Gadget Innovations of 2012]

You may be wondering what exactly you can put in a tablet that sells for just $ 40.41. The 7-inch Android-powered device has 512 MB of RAM, a 1 Ghz processor, 4 GB of flash memory, a multi-touch capacitative screen, front-facing camera, an internal microphone and speakers. The Aakash2 includes a USB hub, an adapter cable, a wall charger and a 12-month warranty.

Sunseet Singh Tuli, DataWind’s CEO and the visionary behind the tablet, points out that Aakash2 wasn’t conceived for the same demographic as the iPad. It’s developed out of the requisite “frugal innovation” that guides India and the developing world.

“Frugal innovation isn’t about creating an iPad killer, it’s about creating an iPad for him,” said Tuli, pointing to a presentation slide of a lower-class man who’s primary motivation is to receive an education. “This is not a straight commerce effort — it’s an educational effort.”

Even the tablet’s name — Aakash, which means sky in Hindi — references that it was created to awaken students’ potential. The government of India has committed to subsidize 50% of the cost of the device for students, making it available for roughly $ 20.

According to DataWind, the technological breakthrough of the Aakash2, which is why the device can be made so inexpensively, is twofold. First, much of its memory and processing power is transfered to backend servers. Second, the parallel processing environment speeds the user experience in remote areas and congested networks.

The Aakash2 also eliminates hardware features deemed unnecessary for the target audience, such as bluetooth and the HDMI interface. It uses open source software to cut costs, as well.

“This tablet seeks to empower the world’s neediest and bridges the digital divide within our society,” said Hardeep Singh Puri, India’s permanent representative to the U.N. at the launch event. “To us, Aakash2 is the epitome of such high end innovation and excellence.”

The Aakash to was designed and developed in Canada, though it was conceived, assembled and programmed in India. DataWind and the Indian government have received criticism because the process is not entirely domestic, though both said they are committed to moving more of the production process to India when cost allows.

The Indian government has committed to equipping all 220 million students in the country with low-cost computing devices and Internet access over the next five years. To put that number in perspective, just 250,000 tablets were sold in India in 2011. It will cost $ 1.6 billion per year at the rate of equipping 40 million students for each of the next five years. The national government has committed to covering half the cost — $ 800 million per year — and will count on state governments and institutions to cover the remaining 50% of costs. Though it sounds like a daunting figure, $ 800 million is only 5% of India’s annual education budget.

“More and more schools in some of the most impoverished areas are using technology, text messaging and mobile applications to enhance the quality of education and open new doors,” said U.N. Secretary General Ban Ki-moon on Wednesday. “Our challenge is to leverage the power of technology and bridge the digital divide.”

During Wednesday’s event at the U.N., Tuli presented Ki-moon with an Aakash2 tablet for each of the U.N. ambassadors.

Not surprisingly, other countries throughout the developing world have noticed the Aakash tablet’s potential. Thailand, Turkey, Sri Lanka, Bolivia, Honduras, Nicaragua, Brazil and Panama have all expressed interest in bringing the low-cost tablet to their students.

“The next arms race is to equip our children with knowledge and information,” Tuli said.

If you’re wondering when you can get your hands on an Aakash2 in the U.S., DataWind plans to begin selling the device in the U.S. in early 2013.

Do you think this low-cost tablet has the power to bridge the digital divide and combat illiteracy? Let us know in the comments.

This story originally published on Mashable here.

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German producers plan Pope Benedict biopic

MUNICH, Germany (Reuters) – Two German producers have bought the film rights to an upcoming biography of Pope Benedict by the Bavarian author of three best-selling interview books with the pontiff.

The Odeon Film company said producers Marcus Mende and Peter Weckert planned a film for international release based on a biography by journalist Peter Seewald due to be published in early 2014.

Seewald’s book-length interviews with Benedict – two as Cardinal Joseph Ratzinger and one as pope – have given readers many insights into the life and thoughts of the shy theologian who now heads the Roman Catholic Church.

Seewald has signed on as a consultant to the scriptwriter, Odeon Film said in a statement on Thursday. It gave no information about the schedule for the film or who might play the main role.

“The producers plan an international film that illustrates all aspects of the extraordinary life and work of Joseph Ratzinger from his birth on Easter night in 1927 in Marktl am Inn in Bavaria to his pontificate today,” it said.

Benedict’s predecessor Pope John Paul was the subject of a dozen documentary films around the world and two major television movies in the United States.

(Reporting by Tom Heneghan; editing by Andrew Roche)

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Geithner predicts Republicans will accept higher tax rates

WASHINGTON (Reuters) – Treasury Secretary Timothy Geithner pressed Republicans to offer a plan to increase revenues and cut government spending, and predicted they would agree to raise tax rates on the wealthiest to secure a deal by year-end to avoid the “fiscal cliff.”

In a blitz of appearances on five Sunday morning talk shows, Geithner insisted that tax rates on the richest needed to go up in order to reach a deal, a step Republicans have so far resisted, and he dismissed much of the contentious rhetoric from last week as “political theater.”

“The only thing standing in the way of would be a refusal by Republicans to accept that rates are going to have to go up on the wealthiest Americans. And I don’t really see them doing that,” Geithner, who is leading the Obama administration‘s fiscal cliff negotiations, said on NBC’s “Meet the Press.”

The comments mark the latest round of high-stakes gamesmanship focusing on whether to extend the temporary tax cuts that originated under former President George W. Bush beyond their December 31 expiration date for all taxpayers, as Republicans want, or just for those with incomes under $ 250,000, as President Barack Obama and his fellow Democrats want.

Republicans, who control the House of Representatives but are the minority in the Senate, have expressed a willingness to raise revenues by taking steps such a limiting tax deductions, but they have largely held the line on increasing rates.

A handful of House Republicans expressed flexibility beyond that of their party leaders about considering an increase in tax rates for the wealthiest, as long as they are accompanied by significant spending cuts.

But most House Republicans refuse to back higher rates, preferring to raise revenue through tax reform.

“There’s not going to be an agreement without rates heading up,” Geithner said bluntly on CNN’s “State of the Union.”

The scheduled expiration of the Bush-era tax cuts and automatic reductions government spending set to take hold early next year would suck about $ 600 billion out of the economy and could spark a recession. The Obama administration and Congress are engaged in talks to avoid the fiscal cliff with a less-drastic plan to reduce U.S. budget deficits.

WHO SHOULD PAY?

Geithner’s Sunday interviews are part of a broader push to build public support for the Democrats’ position in the negotiations. Obama has made campaign-style appearances, including visiting a Pennsylvania toy factory on Friday where he portrayed Republicans as scrooges at Christmas time.

While breaking no new ground on the Obama administration’s position on Sunday, Geithner repeatedly urged Republicans to provide their own plan.

“They said they’re prepared to raise revenues but haven’t said how, or how much, or who should pay,” Geithner said on NBC.

In an interview with the Wall Street Journal on Friday, the Republican leader in the Senate, Mitch McConnell of Kentucky, asked Democrats to accept an increase in the Medicare eligibility age, impose higher Medicare premiums for the wealthy, and slow cost-of-living increases for Social Security.

At least one of those suggestions appears to have White House support. On CNN, Geithner said the administration‘s proposal included a modest rise in premiums for higher-income Medicare beneficiaries.

“What we can’t do is sit here trying to figure out what works for them,” Geithner said. “The ball really is with them now.”

The administration has said it is willing to find savings in the Medicare and Medicaid healthcare programs for the elderly and poor, but Geithner reiterated in an interview with ABC’s “This Week” that it would only be open to looking at changes in the Social Security retirement program outside of the context of a fiscal cliff deal.

(Reporting By Aruna Viswanatha; Editing by Eric Beech)

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Italy votes for center-left candidate for premier

ROME (AP) — Italians are choosing a center-left candidate for premier for elections early next year, an important primary runoff given the main party is ahead in the polls against a center-right camp in utter chaos over whether Silvio Berlusconi will run again.

Sunday’s runoff pits a veteran center-left leader, Pier Luigi Bersani, 61, against the 37-year-old mayor of Florence, Matteo Renzi, who has campaigned on an Obama-style “Let’s change Italy now” mantra.

Nearly all polls show Bersani winning the primary, after he won the first round of balloting Nov. 25 with 44.9 percent of the vote. Since he didn’t get an absolute majority, he was forced into a runoff with Renzi, who garnered 35.5 percent.

After battling all week to get more voters to the polling stations for round two, Renzi seemed almost resigned to a Bersani win by Sunday, saying he hoped that by Monday “we can all work together.”

Bersani, a former transport and industry minister, seemed confident of victory as well, joking about Berlusconi’s flip-flopping political ambitions by asking “What time did he say it?” when told that the media mogul had purportedly decided against running.

Next year’s general election will largely decide how and whether Italy continues on the path to financial health charted by Premier Mario Monti, appointed last year to save Italy from a Greek-style debt crisis.

The former European commissioner was named to head a technical government after international markets lost confidence in then-Premier Berlusconi’s ability to reign in Italy’s public debt and push through sorely needed structural reforms.

Berlusconi has largely stayed out of the public spotlight for the past year, but he returned with force in recent weeks, announcing he was thinking about running again, then changing his mind, then threatening to bring down Monti’s government, and most recently staying silent about his political plans.

His waffling has thrown his People of Freedom party into disarray and disrupted its own plans for a primary — all of which has only seemed to bolster the impression of order, stability and organization within the center-left camp.

A poll published Friday gave the Democratic Party 30 percent of the vote if the election were held now, compared with some 19.5 percent for the upstart populist movement of comic Beppe Grillo, and Berlusconi’s People of Freedom party in third with 14.3 percent. The poll, by the SWG firm for state-run RAI 3, surveyed 5,000 voting-age adults by telephone between Nov. 26 and 28. It had a margin of error of plus or minus 1.36 percentage points.

It’s quite a turnabout for Berlusconi’s once-dominant movement, and a similarly remarkable shift in fortunes for the Democratic Party, which had been in shambles for years, unable to capitalize on Berlusconi’s professional and personal failings while he was premier.

But Berlusconi’s 2011 downfall and a series of recent political party funding scandals that have targeted mostly center-right politicians have contributed to the party’s rise as Italy struggles through a grinding recession and near-record high unemployment.

Angelino Alfano, Berlusconi’s hand-picked political heir, seemed again exasperated Sunday after a long meeting with his patron over Berlusconi’s plans. News reports have suggested Berlusconi might split the party in two and re-launch the Forza Italia party that brought him to political power for the first time in 1994.

“We have to work to reconstruct the center-right, and reconstructing it means having a big center-right party,” not a divided one, Alfano said.

He added that Berlusconi didn’t say one way or another if he would run himself. “It’s his choice,” he said. “If there are any decisions in this regard, he’ll be the one to say so.”

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Microsoft’s next-gen Xbox again said to launch ahead of 2013 holidays

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Glen Campbell considering more live shows in 2013

NASHVILLE, Tenn. (AP) — Glen Campbell may be wrapping up a goodbye tour but that doesn’t mean he’s done with the stage.

Campbell is considering scheduling more shows next year after playing more than 120 dates in 2012.

The 76-year-old singer has Alzheimer’s disease and has begun to lose his memory. He put out his final studio album, “Ghost on the Canvas,” in 2011 and embarked on the tour with family members and close friends serving in his band and staffing the tour.

Campbell’s longtime manager Stan Schneider said in a phone interview from Napa, Calif., where the tour wrapped for the year Friday night, that recent West Coast shows have been some of the singer’s strongest. Campbell will break for the holidays and if he still feels strong he’ll begin scheduling more shows.

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Online:

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South Africa makes progress in HIV, AIDS fight

JOHANNESBURG (AP) — In the early ’90s when South Africa‘s Themba Lethu clinic could only treat HIV/AIDS patients for opportunistic diseases, many would come in on wheelchairs and keep coming to the health center until they died.

Two decades later the clinic is the biggest anti-retroviral, or ARV, treatment center in the country and sees between 600 to 800 patients a day from all over southern Africa. Those who are brought in on wheelchairs, sometimes on the brink of death, get the crucial drugs and often become healthy and are walking within weeks.

“The ARVs are called the ‘Lazarus drug’ because people rise up and walk,” said Sue Roberts who has been a nurse at the clinic , run by Right to Care in Johannesburg’s Helen Joseph Hospital, since it opened its doors in 1992. She said they recently treated a woman who was pushed in a wheelchair for 3 kilometers (1.8 miles) to avoid a taxi fare and who was so sick it was touch and go. Two weeks later, the woman walked to the clinic, Roberts said.

Such stories of hope and progress are readily available on World AIDS Day 2012 in sub-Saharan Africa where deaths from AIDS-related causes have declined by 32 percent from 1.8 million in 2005 to 1.2 million in 2011, according to the latest UNAIDS report.

As people around the world celebrate a reduction in the rate of HIV infections, the growth of the clinic, which was one of only a few to open its doors 20 years ago, reflects how changes in treatment and attitude toward HIV and AIDS have moved South Africa forward. The nation, which has the most people living with HIV in the world at 5.6 million, still faces stigma and high rates of infection.

“You have no idea what a beautiful time we’re living in right now,” said Dr. Kay Mahomed, a doctor at the clinic who said treatment has improved drastically over the past several years.

President Jacob Zuma’s government decided to give the best care, including TB screening and care at the clinic, and not to look at the cost, she said. South Africa has increased the numbers treated for HIV by 75 percent in the last two years, UNAIDS said, and new HIV infections have fallen by more than 50,000 in those two years. South Africa has also increased its domestic expenditure on AIDS to $ 1.6 billion, the highest by any low-and middle-income country, the group said.

Themba Lethu clinic, with funding from the government, the United States Agency for International Development and the President’s Emergency Plan for AIDS Relief, is now among some 2,500 anit-retroviral therapy facilities in the country that treat approximately 1.9 million people.

“Now, you can’t not get better. It’s just one of these win-win situations. You test, you treat and you get better, end of story,” Mahomed said.

But it hasn’t always been that way.

In the 1990s South Africa’s problem was compounded by years of misinformation by President Thabo Mbeki, who questioned the link between HIV and AIDS, and his health minister, Manto Tshabalala-Msimang, who promoted a “treatment” of beets and garlic.

Christinah Motsoahae first found out she was HIV positive in 1996, and said she felt nothing could be done about it.

“I didn’t understand it at that time because I was only 24, and I said, ‘What the hell is that?’” she said.

Sixteen years after her first diagnosis, she is now on anti-retroviral drugs and her life has turned around. She says the clinic has been instrumental.

“My status has changed my life, I have learned to accept people the way they are. I have learned not to be judgmental. And I have learned that it is God’s purpose that I have this,” the 40-year-old said.

She works with a support group of “positive ladies” in her hometown near Krugersdorp. She travels to the clinic as often as needed and her optimism shines through her gold eye shadow and wide smile. “I love the way I’m living now.”

Motsoahae credits Nelson Mandela’s family for inspiring her to face up to her status. The anti-apartheid icon galvanized the AIDS community in 2005 when he publicly acknowledged his son died of AIDS.

None of Motsoahae’s children was born with HIV. The number of children newly infected with HIV has declined significantly. In six countries in sub-Saharan Africa — South Africa, Burundi, Kenya, Namibia, Togo and Zambia —the number of children with HIV declined by 40 to 59 percent between 2009 and 2011, the UNAIDS report said.

But the situation remains dire for those over the age of 15, who make up the 5.3 million infected in South Africa. Fear and denial lend to the high prevalence of HIV for that age group in South Africa, said the clinic’s Kay Mahomed.

About 3.5 million South Africans still are not getting therapy, and many wait too long to come in to clinics or don’t stay on the drugs, said Dr. Dave Spencer, who works at the clinic .

“People are still afraid of a stigma related to HIV,” he said, adding that education and communication are key to controlling the disease.

Themba Lethu clinic reaches out to the younger generation with a teen program.

Tshepo Hoato, 21, who helps run the program found out he was HIV positive after his mother died in 2000. He said he has been helped by the program in which teens meet one day a month.

“What I’ve seen is a lot people around our ages, some commit suicide as soon as they find out they are HIV. That’s a very hard stage for them so we came up with this program to help one another,” he said. “We tell them our stories so they can understand and progress and see that no, man, it’s not the end of the world.”

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South Korea November exports show fragile, uneven global recovery

SEOUL (Reuters) – South Korean exports last month marked their first back-to-back growth of the year, but demand from the advanced economies was weak, data showed on Saturday, indicating any global recovery would be fragile at best.

November exports grew by 3.9 percent over a year earlier to $ 47.8 billion on top of a revised 1.1 percent rise in October, while imports last month rose by 0.7 percent to $ 43.3 billion, the Ministry of Knowledge Economy data showed.

The November data, released for the first time by a major exporting economy, and the robust survey findings in China disclosed earlier in the day offered fresh signs of the global economy regaining some momentum.

Shipments to China and the southeast Asian countries posted sharp gains over a year earlier, whereas demand from the United States and the European Union shrank, according to break-down figures for the November 1-20 period released later.

“Robust data from China and today’s Korean data increase the chances for Korean exports maintaining a modest recovery,” said Park Sang-hyun, chief economist at HI Investment & Securities.

RARE ANNUAL DROP IN EXPORTS

Data released earlier on Saturday showed China’s manufacturing sector activity was at a seven-month high in November, while South Korea’s October industrial output also expanded for the second straight month.

“But as Europe and the U.S. are not getting any stronger soon, any global recovery will be an uneven and fragile one for the time being,” Park added.

Analysts in a Reuters survey had forecast November exports would grow a median 2.6 percent over a year before on top of a revised 1.1 percent gain in October, when overseas sales posted their first growth in four months.

The ministry’s data showed South Korea ran a trade surplus of $ 4.48 billion for November, compared with a revised surplus of $ 3.73 billion in October. The country’s trade balance has been in black for all but two months since early 2009.

Meanwhile, exports for the January-November period were 0.8 percent less than the comparable period of 2011, making it highly likely the country will miss its export target of a 3.5 percent gain set for the whole of 2012.

Reuters calculations show South Korean exports this year would post an annual loss unless shipments in December grow 9 percent or more on a year-on-year basis. The country’s exports grew in all but three years for the past 50 years at least.

South Korea is home to some of the world’s largest suppliers of cars, smartphones and ships. It sends roughly a quarter of its total exports to China and about 10 percent each to the European Union and the United states.

(Editing by Ron Popeski)

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Cargo plane crashes in Brazzaville, 3 dead

BRAZZAVILLE, Republic of Congo (AP) — A cargo plane owned by a private company crashed Friday near the airport in Brazzaville, the capital of the Republic of Congo, killing at least three people, officials said.

The Soviet-made Ilyushin-76 belonged to Trans Air Congo and appeared to be transporting merchandise, not people, said an aviation official who requested anonymity because he was not authorized to speak to the media.

The plane was coming from Congo‘s second-largest city, Pointe Noire, and tried to land during heavy rain, he said.

Ambulances rushed to the scene in the Makazou neighborhood, located near the airport, but emergency workers were hampered by the lack of light in this capital, which like so many in Africa has a chronic shortage of electricity.

“At the moment, my team is having a hard time searching for survivors in order to find the victims of the crash because there is no light and also because of the rain,” Congolese Red Cross head Albert Mberi said.

He said that realistically, they will only be able to launch a proper search Saturday, when the sun comes up.

Reporters at the scene fought through a wall of smoke. Despite the darkness, they could make out the smoldering remains of the plane, including what looked like the left wing of the aircraft. A little bit further on, emergency workers identified the body of the plane’s Ukrainian pilot, and covered the corpse in a blanket.

Firefighters were trying to extinguish the blaze of a part of the plane that had fallen into a ravine. They were using their truck lights to try to illuminate the scene of the crash. Although the plane was carrying merchandise, emergency workers fear that there could be more people on board.

Because of the state of the road connecting Pointe Noire to Brazzaville, many traders prefer to fly the roughly 400 kilometers (250 miles).

Africa has some of the worst air safety records in the world. In June, a commercial jetliner crashed in Lagos, Nigeria, killing 153 people, just a few days after a cargo plane clipped a bus in neighboring Ghana, killing 10.

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EBay’s double tax base prompts calls for investigation

LONDON (Reuters) – Britain and Germany may have missed out on a combined $ 1 billion in sales tax since online marketplace eBay picked a tiny Luxembourg office as its base for EU sales, a shift that lawmakers say should now be investigated.

EBay’s nomination of Luxembourg unit eBay Europe Sarl – with a staff of nine – as its provider of services to EU clients allows it to charge customers in Europe a low rate of sales tax, often known as Value Added Tax, helping it to compete against rivals.

However, the unit doesn’t actually receive the money from sales. Instead, eBay said it continues to channel revenues through a Berne-based unit, allowing the company also to benefit from what Swiss tax lawyers say is the most competitive corporate income tax regime in Europe.

EU rules allow companies to establish subsidiaries in Luxembourg and levy VAT at Luxembourg’s low VAT rate on sales to customers across the bloc.

However, the rules also allow individual EU taxmen to challenge any claim to Luxembourg residence, and the right to charge Luxembourg VAT, in their domestic courts, if the taxman feels a Luxembourg-based subsidiary does not have sufficient staff or assets to support its claim to be the true supplier of goods or services.

Tax experts say eBay’s arrangement, which appears to give eBay the best of both income and sales tax worlds, could be open to challenge, and lawmakers in the UK and Germany want their taxmen to investigate.

“I hope that HMRC (UK tax authority Her Majesty’s Revenue and Customs) takes note … and takes prompt action,” said Margaret Hodge, member of parliament and chairman of the Public Accounts Committee (PAC), which monitors government finances.

“I will be seeking assurance that they are, next time we take evidence from HMRC,” she added. Officials from HMRC are due to testify to the PAC in early December as part of the committee’s investigation into tax matters.

Sven Giegold, member of the European Parliament for Germany’s Green Party, said he wanted the German tax authorities to “have a very critical look at this”.

It is common for companies to seek to reduce their tax bills, and a number of multinationals have established bases in Luxembourg so they can charge customers lower levels of VAT.

EBay said HMRC was aware of all its tax arrangements and that it was confident it met all its tax liabilities in the UK and elsewhere.

“In all countries and at all times, eBay is fully compliant with national, EU and international tax rules (including the OECD) including the remittance of VAT to the appropriate authorities,” an eBay spokesman said in an emailed statement.

The UK, German, French and Luxembourg tax authorities declined to comment on eBay, citing rules on taxpayer confidentiality.

LOWER THRESHOLD

Big companies’ tax practices have risen to the top of the political agenda in Europe in the past year, with lawmakers growing increasingly frustrated with the way in which companies such as search engine company Google pay almost no income tax in countries where they have billions of dollars in sales.

The companies escape liability for income taxes in countries like the UK by arguing the value created by their business, and therefore the location where the profit should be realized, is not the place where the customer resides, but rather in the location where the intellectual property underpinning the product or service is based.

Chas Roy-Chowdhury, head of taxation at the Association of Chartered Certified Accountants, said this was a valid economic argument and that if, for example, HMRC wants to claim more income tax from Google, it has to prove the company is generating more value in the UK than it is declaring.

This would require a thorough deconstruction of its business model and supply chain.

However, it is easier to establish liability to VAT, since this tax hinges simply on the location of the buyer and seller.

“The threshold is lower,” said Simon Newark, head of VAT at accountants UHY Hacker.

“There are a lot more aspects for HMRC to challenge in VAT than in direct (income) tax.”

For tax purposes, the EU deems eBay’s online platform an “electronically supplied service”, a category that also covers e-Books and music downloads.

Under EU rules, suppliers of such services based within the bloc are supposed to charge EU customers VAT at the rate prevailing in the country where the supplier is based.

A number of suppliers of electronic services, including Amazon.Com Inc and Apple Inc’s iTunes have established European headquarters in Luxembourg to enable them to charge customers lower VAT rates than prevail in their customers’ countries.

Luxembourg has traditionally charged the lowest standard VAT rates in the European Union. Its 15 percent rate compares with rates of 19-25 percent in most other EU members.

By charging customers VAT at Luxembourg’s rate eBay is better able to compete with rivals based elsewhere in the EU, such as Britain’s eBid, which must charge customers VAT at the standard UK rate of 20 percent.

However, to be entitled to charge Luxembourg rates, a company has to be able to prove in British, German or EU courts that it is genuinely based in the Grand Duchy.

Companies selling to EU customers from outside the EU – as eBay was until the 2007 nomination of eBay Europe Sarl as supplier to EU clients – must charge European customers VAT at the rate prevailing in the country where the customer resides, and to pay that VAT to the taxman in the customer’s country.

There is no definitive checklist that determines the true base of a company and any decision by a national court can be challenged in the European Court of Justice. In the UK, HMRC said it approached the matter on a case-by-case basis, and disputes are often resolved in court.

“HMRC will challenge any arrangements where it is claimed that supplies are made from a particular country but the business does not have the necessary resources to make those supplies,” a spokesman said.

EUROPE EXPANSION

EBay, which is headquartered in San Jose, California, moved into Europe in 1999 when it established eBay International in Berne. Switzerland’s low income tax regime for foreign companies was highly beneficial for the auction site. “We do have a very favorable international tax structure,” then-Chief Financial Officer Rajiv Dutta told analysts in 2002 when asked how the company managed to pay such low taxes on its non-U.S. income.

The Swiss base also meant, initially, that the company didn’t have to charge EU customers VAT. But in 2003, Brussels changed the rules, which forced eBay to charge EU sellers on its platform VAT based on their residence. The VAT gathered was remitted to the tax authority in the customer’s country.

Not all customers are charged VAT. Most medium-sized and big businesses are legitimately exempted from paying VAT on some purchases, such as eBay seller fees.

EBay’s Swiss-based European public relations head declined to say what portion of its EU customers were liable to be charged VAT. James Cordwell, equities analyst at Atlantic Equities, estimated that such customers accounted for 40-50 percent of sales in Europe.

Since the 2007 creation of its Luxembourg operation, eBay has had German fee revenues of $ 6.1 billion and UK revenues of $ 5 billion, its annual accounts show.

If the services were supplied from Switzerland or another non-EU country, and assuming only half of customers should have been charged VAT, EU rules would have obliged eBay to collect $ 580 million in VAT for the German taxman and $ 500 million in VAT for HMRC since 2007.

EBay’s entitlement to charge Luxembourg VAT on sales and to pay this to the Luxembourg taxman rests on being able to prove in court that eBay Europe Sarl is the provider of services to EU clients.

But despite German and UK fee income of $ 3.1 billion last year, eBay Europe Sarl recorded turnover of only 5 million euros in 2011.

John Hemming, an MP with the Liberal Democrats, the junior partner in the British coalition government, said the fact eBay’s sales revenues did not go through the Luxembourg unit undermined the claim that it was the true provider of services to EU clients.

“If it’s a real transaction, you would expect the money to pass with it, and not pass someplace else,” he said.

Rather than going to Luxembourg, the money generated from customers continues to go to Berne-based eBay International AG, a spokeswoman said.

When Reuters visited in mid November, staff at the Luxembourg office, just opposite the central post office, declined to discuss what operations the unit conducted for eBay.

A spokesman later said the office conducted activities including billing, data privacy, contracting, regulatory, management and some customer services operations.

By contrast, Amazon and iTunes do report their sales of ebooks and music downloads to EU customers through their Luxembourg units.

Prem Sikka, professor of accounting at Essex University, along with Newark and Roy-Chowdhury said a cash trail through a unit was one of the key factors used as evidence that the unit was the true supplier of a service.

UK and German tax authorities could argue that the shift in eBay’s supply base to Luxembourg from Berne was therefore not genuine. If successful, they could claim back the VAT lost.

EBay declined to say why it channeled sales through Switzerland. Tax advisors say the country can still offer some companies lower tax rates than other European low-tax jurisdictions such as Ireland and Luxembourg.

Indeed, EBay’s closest rival Amazon, which channels about half its non-U.S. earnings through Luxembourg, reported average income tax on overseas earnings of 6 percent in the past four years. EBay paid just 3 percent over the same period.

(Additional reporting by Brenda Goh; Editing by Will Waterman)

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