‘Two or three’ companies are set to follow Shire and move offshore for tax
reasons in the next month or two, according to a senior tax adviser.
Bill Dodwell, a partner at Deloitte, said the rumour in the market was that
similar deals were ready to go, and would be announced shortly.
decision to set up a holding company resident in Ireland is thought to be a
response to the foreign profits changes being consulted on by the Treasury.
The government is attempting to clamp down on companies putting income
producing assets in low-tax offshore locations.
It is trying to define what it calls ‘passive’ income – for example putting a
Treasury function offshore – and ‘active’ income deriving from genuine economic
But the consultation has caused an uproar among corporates, who feel they
will face huge and unfair new tax bills, as well as huge compliance costs
associated with figuring out what is active and what is passive income.
Companies with brands and intellectual property are particularly concerned,
since they are more mobile.
‘My advice is why don’t you wait and see what the outcome of the foreign
profits review really is? If you think it’s terrible you will have enough time
to depart,’ Dodwell said.
The suggestion that more corporates are ready to leave will cause concern in
the Treasury, sensitive to suggestions that the UK is uncompetitive on tax.
Does Darwin's theory apply to taxation? Colin ponders...
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