Shire plc, one of the UK's largest drug makers, has announced plans to "protect
the group's taxation position" by establishing a holding company in Jersey
and moving the company's residence for tax purposes to Ireland.
In an announcement made on 15th April, Shire stated that the move will not result
in any changes in the day to day conduct of the company's business, its strategy
or dividend policy.
The new holding company will have its primary listing on
the London Stock Exchange (LSE) and its American Depositary Shares (ADS) will
be traded on NASDAQ. It is not planned that the proposals will result in any
job losses or relocation of existing Shire personnel out of the UK.
While the plans are being interpreted by tax experts as an indictment against
the UK's corporate tax regime, Shire argued that the proposals are motivated
by the fact that the company has become increasingly international, and that
only a small proportion of its revenue is now generated within the UK.
"Shire has concluded that its business and its shareholders would be better
served by having an international holding company with a group structure that
is designed to help protect the group’s taxation position, and better
facilitate the group’s financial management. The Directors believe that
the most appropriate structure is for the new group parent company to be tax-resident
in the Republic of Ireland," the company statement explained.
Corporate tax in the UK was cut to 28% from 30% this year, but whereas the
UK once had the third lowest rate in the EU in 1997, it is now the sixth highest,
and the effective average corporation tax rate is the eighth highest in the
OECD, according to the Confederation of British Industry (CBI). By contrast,
corporate tax is 12.5% in Ireland.
The new holding company, which is to be called Shire Limited, will have the
same board and management team as Shire, and there will be no substantive changes
to corporate governance and investor protection measures, accoridng to the statement.