Black Wednesday

They called April 6th “Black Wednesday” in the UK. Well, I heard someone say that on the BBC. It’s because it was the start of the new tax year, and since the government maxed out the credit card, the payments are going up. There’s going to be some pressure to collect to more tax, because there’s a limit to how much you can put the rates up before avoidance (and emigration) reduces the total amount collected. I wonder if we will soon be going down the Greek route.

The Greek government announced Thursday it is shutting down bars and nightclubs… that fail to offer receipts. So far, six bars and clubs have been shut down as par of a broader sweep where two-thirds of all inspected businesses were fined. The absence of receipts allows businesses to avoid value added tax, or consumption tax, the Ministry of Finance said in a press release.

[From Euro Debt Crisis – Cash-Strapped Greece Cracks Down on Fun – CNBC]

Now this could be good for the e-payments industry, because the easiest away to avoid receipts and therefore evade tax is to pay in cash. Here, in the birthplace of income tax, the government are apparently going to have something of a crackdown on tax evasion.

HMRC has targeted so-called ‘ash cash’ or payments to doctors for signing death certificates before bodies can be cremated and also undeclared cash payments to dentists.

[From HMRC targets middle class tax evaders – Telegraph Blogs]

This seems on the margin to me: I shouldn’t think the amount of tax being evaded by doctors writing death certificates will amount to one payoff of a local government official and I have to say that none of my dentists has ever asked me for a cash payment for anything.

It could even be argued that agreeing to pay your builder in cash might be seen as a conspiracy to defraud the Revenue

[From HMRC targets middle class tax evaders – Telegraph Blogs]

Now you’re talking! Agreeing to pay your builder in cash is precisely engaging in a conspiracy to evade tax, and people who do it should be prosecuted. If they paid their share, mine wouldn’t be so much.

And it’s not just that carrying around cash is inconvenient and time consuming. These days, one of its main functions is to finance the black economy: drug deals, counterfeiting, under-the-table employment and other nefarious activities. Because cash is anonymous, people can easily opt out of the taxable economy – leaving the rest of us to pick up the tab for their use of public services.

[From I’m dreaming of a cashless Christmas – Telegraph]

Getting rid of cash won’t eradicate tax evasion, but it will make it more difficult, and hopefully more expensive, thus shifting otherwise black commerce back into the formal economy. And since the scale of tax evasion in Europe is so colossal, small improvements will deliver significant sums to the treasuries. I couldn’t find a reasonable estimate for this in the most recent tax year, but I did find this estimate for VAT alone.

The current collection model brings with it a VAT Gap due to e.g. VAT fraud, insolvencies, mistakes by the taxable persons in the VAT return and VAT avoidance schemes. Desk research shows that the VAT Gap for 2009 can be cautiously estimated at 6,9% of GDP and 12% of total VAT liability in the EU-27. This means that, in the EU-27, a total of EUR 118,8 billion has according to those estimates not been collected by the tax authorities in 2009.

[From 118,8bn euros lost in 2009]

Let’s say that 20 billion of this is in the UK, and that getting rid of cash would cut it by a quarter. That’s an instant five billion bonus to the exchequer. I look forward to my rebate.

iPown

To understand why the fuss, and why this is of relevance to the digital money world, you need to understand a couple of technical architectures relating to mobile phones and the role of the Secure Element (SE). The SE doesn’t exist in phones yet, but it’s important because if we want to implement anything important (such as payments) inside a phone, we need somewhere to store cryptographic keys, and that somewhere needs to be tamper-resistant to a great degree. Thus we need a handset to have an SE. Ah! You might say: but handsets already have a tamper-resistant thingumy inside them, why not use that?

That’s a good point. In the modern way of things, the tamper-resistant chip thingumy the handset is more properly called the UICC:

The UICC (Universal Integrated Circuit Card) is the smart card used in mobile terminals in GSM and UMTS networks. The UICC ensures the integrity and security of all kinds of personal data, and it typically holds a few hundred kilobytes. With the advent of more services, the storage space will need to be larger.

[From UICC – Wikipedia, the free encyclopedia]

Historically, we’ve tended to associate the UICC (in the form of a removable smart card) with one application only, and that application is the Subscriber Identification Module (SIM) that allows the phone to connect to a mobile network and refer to the combination as “the SIM”. But…

A UICC may contain several applications, making it possible for the same smart card to give access to both GSM and UMTS networks, and also provide storage of a phone book and other applications

[From UICC – Wikipedia, the free encyclopedia]

It can also contain more than one of each. Thus, you could have multiple “soft SIMS” inside one UICC (that special case where the UICC contains only one application, and that is a SIM, we will refer to henceforth as the “hard SIM”). Now let’s consider what happens when Apple add an NFC interface to their devices and therefore need an SE.

The filing also points to the inclusion of near-field communication (NFC) technology in upcoming iPhones — and, for that matter, in Macs and media devices such as the Apple TV.

[From Apple patent seeks to reinvent retail • The Register]

Where can the SE that makes the NFC interface useful go? Either we can plug in an SE (eg, a DeviceFidelity microSD) or we can add an SE to the UICC (the e GSM Association, GSMA, preferred option) or we can build an SE into the device by adding it to the motherboard. The GSMA want to put the applications that control the NFC interfaces to be on the UICC, which kind of makes sense because if you take your UICC out of one phone and put it in another, then you’d want your SE applications (eg, your MasterCard, Oyster etc) to go with it. But not everyone thinks that the SIM is the key to this picture.

Suppose that instead of adding an SE, Apple add a UICC and put the SE in that? What this means in practice is that the UICC will be inside the iPhone or iPad or Mac, on the motherboard. But the SE need not be the only contents of the UICC. Why not put soft SIMs in there as well and do away with fiddly microSIMs? If I walk into the Apple Store in London and buy a 3G iPad, say, then the UICC could come with a default SIM application. Let’s say this is O2. When I take the iPad to France, instead of paying outrageous 3G roaming charges (and therefore leaving my iPad at home), my iPad will download a French operator’s SIM application and start using that. I won’t choose the operator — in fact I won’t even know this is going on, because Apple will simply negotiate with mobile operators to provide commodity service.

In other words, perhaps we move to a world in which the operators’ SIM connectivity function becomes just software running on someone else’s physical card.

[From Dean Bubley’s Disruptive Wireless: Apple, embedded SIMs, NFC and mobile payments – some speculation]

Dean is spot on. And you can see plenty of positives in this architecture. If you’re not a mobile operator, that is. If you’re a mobile operator, this is another step towards being nothing more than a pipe. As a customer, I think I’d be quite happy with the mobile operators as a pipe, selected purely on a cost/QoS basis (and competing with each other on that basis). After all, they haven’t (in Europe) got very far with “smart pipe” services such as, just to name two examples, digital money and digital identity. So the Apple UICC containing soft SIMs and an SE may not be such a bad architectural option for consumers. But…

The operators are privately saying they could refuse to subsidise the iPhone if Apple inserts an embedded subscriber identity module, or Sim card.

[From FT.com / Telecoms – Apple warned over built-in Sim cards]

There are other people in this value chain too, such as smart card manufacturer Gemalto who were rumoured to be making the Apple UICC.

Gemalto explained to us why such a deal, which involved a significant amount of devolution from the mobile phone operators to the mobile phone manufacturers, is unlikely to happen without the tacit approval of network carriers themselves.

Gemalto has been a strategic partner for mobile phone operators for more than a decade now (the company is the biggest SIM manufacturer in the world) and gets the majority of its revenue (more than 60 per cent of last year’s 1.654 billion Euros).

[From Gemalto : No Apple iPhone 5 Deal On The Table Yet | ITProPortal.com]

Quite. But let’s just go back over another main point: in order to provide payments, or other useful services, via NFC it is not necessary to have the co-operation of the carriers.

Visa’s approach “shows that basically there’s nothing that the carriers can do that the [payment] networks can’t do without them,” McPherson said.

[From Mobile Payments Set for Surge, But Who ll Set the Pace? – American Banker Article]

The mobile operators have no acceptance at retail POS so they have to work with payment scheme partners to reach scale, but other payments players don’t need the operators. They can put stickers on the back of phones, plug microSD into handsets or use the NFC interfaces that will be built in by Google, Apple and RIM. Since customers will come to expect these services, they will eventually get built in to all handsets. Unless the operators can launch highly functional NFC platforms quickly (which they probably should have started doing a couple of years ago) then they will be out of the loop.

Issuing hard SIMs is expensive, so if the operator’s connection with the customer is downgraded, there is no point in doing it and the operators would save money by providing soft SIMs to any UICC that they can bill to. So I think the situation is this: in the future, many devices will a UICC built-in. This UICC will function as an SE for NFC interfaces. The UICC will store a number of soft SIMs, not only for mobile phone communications but for future 4G and 5G communications. The UICC will also hold standard digital money and digital identity applications. And instead of Vodafone and Telefonica controlling the matrix, Apple and Google will.

These opinions are my own (I think) and presented solely in my capacity as an interested member of the general public [posted with ecto]


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