Treasury urged to revisit foreign profits

Companies are seeking a further meeting with the Treasury to hammer out a more palatable regime for taxing foreign profits of UK-based multi-nationals

Written by Barbara Buchanan

The move follows the departure of Shire, the UK’s third largest pharmaceutical firm, to Ireland for its tax residency, with United Business Media following suit this week.

John Fairley, an international tax adviser with law giant Baker & McKenzie, who has met the Treasury as a representative of the International Chambers of Commerce in an earlier stage of the consultation, said: ‘Obviously, recent developments should have affected the government’s thinking, this is a real concern for all of us. They need to sit up and pay attention to it.’

Other leading figures consulted on the Treasury’s original discussion document, released last June, and agreed an urgent meeting was needed. Ian Brimicombe, tax director for AstraZeneca and a member of the Hundred Group of Finance Directors’ fiscal committee, said: ‘There must be further interaction to ensure issues are fully fleshed out prior to the consultation document.’

He said AstraZeneca had already made a representation to Treasury officials making its opposition on the taxation of passive income clear.

Brimicombe said: ‘We are engaging with them to work through a sensible and proportional regime which allows the UK to prove itself as a competitive regime alongside other countries.’

Brimicombe added that the Hundred Group was keen for the UK to remain a country that large organisations find attractive to invest in and from.

GSK’s outgoing chief executive, Jean-Pierre Garnier, has said that the UK business environment needed to be ‘realistic and favourable’ to enable multi-nationals to compete globally.

The Treasury’s discussion document on reforming UK rules for controlled foreign companies, CFCs, outlined a move to tax passive income ­ such as dividends, interest, annuities, royalties and rents of overseas subsidiaries.

It has been conducting its consultation on the moves directly with corporate representatives.

A Treasury spokesman said: ‘We will continue to discuss with businesses the way in which the new CFC tax regime can be designed. The principal will be to increase competitiveness and any proposals will reflect our ongoing discussions with businesses.’

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