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Traditionally, in state and international tax jurisdiction situations, the taxable jurisdiction of a sale is the jurisdiction in which the client/customer sits. However, jurisdiction may also extend to the jurisdiction of the seller (or even to a third jurisdiction) if the sale was negotiated and executed/agreed to outside of the customer's jurisdiction.

So in a nutshell...you shouldn't have nexus just because you sell on Google Play...but if you're really worried about it you should consultant with a lawyer or an accountant (because for some reason accountants can opine on tax law).

Why is there no nexus formed by the owner of the app store but just the independent dev selling the software? For example, why is the only nexus formed my state of Indiana(ie my location) and not Google's app store location?

That's not the case, whatever Google claims. Google is trying to claim to be just a service provider for your sale (i.e., just facilitating the transaction) but the store TOS, its policies, and Google's actions demonstrate that Google is acting more like a retail store than a sales service provider. Legally, and especially in the tax world, this makes a tremendous difference. (This ridiculous stance is also why Google Play's international market availability (in terms of countries) is so much smaller than the Apple or Microsoft store. Google knows its claims won't fly in most countries, so it has to stay out of those countries to avoid very significant fines and penalties.)



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