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One of Britain’s largest drugs companies is to move its headquarters to Dublin
in an effort to limit its tax bills. Accountants say that this could be just
the beginning of a spate of similar moves by other UK multinationals.
Shire, the UK’s third-biggest pharmaceutical company, will incorporate its new
holding company in Jersey and hold all board meetings in Dublin. Its
operations and 300 staff will remain in Basingstoke, Hampshire.
The move is understood to be a result of disquiet about a possible government
crackdown on profits from offshore subsidiaries. Most UK companies do not
pay corporation tax on offshore profits that are kept overseas unless the
foreign subsidiary is deemed to have been set up to avoid tax. However, all
firms must pay corporation tax of 28 per cent on all profits brought into
the UK, “topping up” any lesser tax already paid in another country to the
UK level.
The Government is reviewing this top-up policy, but it is feared that it may
also widen the scope of antiavoidance measures, making new rules ultimately
more onerous than the present ones.
Accountants also say that many firms have grown tired of waiting for the
outcome of a consultation that began more than two years ago.
Chris Sanger, head of tax policy for Ernst & Young, the accountancy firm,
said: “By delaying the new rules, the Government are exposing themselves to
the risk that companies will take action. Quite a few other multi-national
companies with overseas activities are quite far down the road of seeking
alternative tax headquarters so they can be sure of the tax charges they
face.
“Inertia has kept them here, but in today’s economic climate they are looking
at all their expenses - including tax.”
The Irish Republic’s corporation tax rate of 12.5 per cent is less than half
that of the UK. Shire, a FTSE 100 company that is worth more than £5
billion, will continue to pay UK corporation tax on UK profits, as well as
UK national insurance and VAT.
The CBI expressed alarm that other firms could take similar action. Richard
Lambert, the Director-General of the CBI, told an audience: “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
internationally mobile firms will follow Shire’s path.” Mr Lambert added:
“Readings on the UK’s entrepreneurial barometer have dipped sharply over the
past 12 months.”
Vince Cable, the Liberal Democrat Treasury spokesman, said: “The Government
can’t afford to dither. It doesn’t seem to be aware of the tax competition
issues.”
However, the Treasury maintained that Britain still had one of the most
competitive tax regimes in Europe. A Treasury spokesman said: “We have the
lowest headline rate of corporation tax in the G7, and tax is only one
factor which makes us the best place to do business. We have a highly
skilled workforce and first-rate infrastructure.”
Adam Bainbridge, the head of corporate tax for KPMG, said: “It would be better
for the Government to go back and look at the underlying problem here, which
is the competitiveness of the UK tax system as a whole.”
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