http://www.ft.com/cms/s/0/737135da-0...79fd2ac.html:p
UK drugmaker moves tax domicile to Ireland
By Salamander Davoudi and Andrew Jack in London
Published: April 15 2008 20:33 | Last updated: April 15 2008 20:33
Shire, the FTSE 100 pharmaceutical group, on Tuesday dealt a blow to the UK as a corporate location by announcing it was moving its tax domicile to Ireland.
While the group’s operations will keep its headquarters in the UK, the holding company will be incorporated in Jersey, and pay reduced tax on global earnings in Ireland, where the headline corporate rate is just 12.5 per cent.
Shire, which generates the majority of sales outside Britain, declined to say how much it expected to save by the move. It paid £9m in UK tax in 2006, of which £4m was corporation tax.
Richard Lambert, CBI director-general, said in response to the move: “We are particularly worried that an uncompetitive corporate tax system is spoiling the UK’s attractiveness as a place to do business, and that other... firms will follow Shire’s path.”
Shire insisted the change would not make any difference to its operations, employees or primary listing on the London Stock Exchange and other listing on Nasdaq. Under the new arrangements, board meetings will be held in Ireland.
Angus Russell, Shire’s chief executive, told the Financial Times earlier this year he was increasingly focused on Ireland, where low tax rates tempt manufacturing investment and patent registration. “The era of paper transactions and occasional board meetings in order to have intellectual property in the Caymans, Bermuda and the Bahamas has ended, with a shift to substance over form,” he said.
The company already has an office in Dublin where it employs 55 people and has sales and marketing operations. Most of Shire’s intellectual property assets are in the US and Ireland.
Shire looked at a number of jurisdictions, including Switzerland, but settled on Ireland as the company was already established there, it is easy to get to and is English-speaking.
Shire’s move will be effected through a new holding company based in Jersey, and shareholders will receive shares in the new company on a one-for-one basis. They will in future be able to decide whether to take dividends from a UK tax resident company or an Irish one. Royalties on patents that are lodged in Ireland are tax free, making the country particularly attractive for life sciences companies.
Navid Malik, analyst at Collins Stewart, said: “This becomes a big deal if we see AstraZeneca and GlaxoSmithKline trying to do the same thing. This is sending the wrong message.”
UK drugmaker moves tax domicile to Ireland
By Salamander Davoudi and Andrew Jack in London
Published: April 15 2008 20:33 | Last updated: April 15 2008 20:33
Shire, the FTSE 100 pharmaceutical group, on Tuesday dealt a blow to the UK as a corporate location by announcing it was moving its tax domicile to Ireland.
While the group’s operations will keep its headquarters in the UK, the holding company will be incorporated in Jersey, and pay reduced tax on global earnings in Ireland, where the headline corporate rate is just 12.5 per cent.
Shire, which generates the majority of sales outside Britain, declined to say how much it expected to save by the move. It paid £9m in UK tax in 2006, of which £4m was corporation tax.
Richard Lambert, CBI director-general, said in response to the move: “We are particularly worried that an uncompetitive corporate tax system is spoiling the UK’s attractiveness as a place to do business, and that other... firms will follow Shire’s path.”
Shire insisted the change would not make any difference to its operations, employees or primary listing on the London Stock Exchange and other listing on Nasdaq. Under the new arrangements, board meetings will be held in Ireland.
Angus Russell, Shire’s chief executive, told the Financial Times earlier this year he was increasingly focused on Ireland, where low tax rates tempt manufacturing investment and patent registration. “The era of paper transactions and occasional board meetings in order to have intellectual property in the Caymans, Bermuda and the Bahamas has ended, with a shift to substance over form,” he said.
The company already has an office in Dublin where it employs 55 people and has sales and marketing operations. Most of Shire’s intellectual property assets are in the US and Ireland.
Shire looked at a number of jurisdictions, including Switzerland, but settled on Ireland as the company was already established there, it is easy to get to and is English-speaking.
Shire’s move will be effected through a new holding company based in Jersey, and shareholders will receive shares in the new company on a one-for-one basis. They will in future be able to decide whether to take dividends from a UK tax resident company or an Irish one. Royalties on patents that are lodged in Ireland are tax free, making the country particularly attractive for life sciences companies.
Navid Malik, analyst at Collins Stewart, said: “This becomes a big deal if we see AstraZeneca and GlaxoSmithKline trying to do the same thing. This is sending the wrong message.”
Comment