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UBM Opts To Pay Tax In Ireland
by Jason Gorringe, Tax-News.com, London

01 May 2008

United Business Media plc (UBM) has announced plans to relocate its tax residency from the UK to the Republic of Ireland to take advantage of the latter country's "less complex system of taxation".

Under the proposals, a new UBM holding company would be created which is UK-listed, incorporated in Jersey, but resident for tax purposes in Ireland.

If the plan is approved by shareholders, UBM will be following in the footsteps of drug maker Shire, which on 15th April announced proposals for a similar corporate structure to "protect the group's taxation position".

According to UBM's statement announcing the plans, released on Monday, the new structure reflects the development of UBM into an international business-to-business media and news distribution organisation, which operates in more than 30 countries worldwide and now generates more than 85% of its profits outside the United Kingdom.

UBM’s major international brands include PR Newswire, Game Developer Conference, Interop and CPhI.

The company expects the proportion of its earnings generated overseas to continue to grow, as it continues its strategy of building businesses internationally, particularly in fast-growing economies such as China, India, Latin America and the Middle East.

During the last three years, UBM has invested GBP386mn (USD759mn) in 52 acquisitions, 39 of which, totalling GBP310mn, have been made outside the UK.

During this period, UBM has further expanded its international presence, opening a significant number of new offices, including in Chengdu, Mumbai, Sao Paulo and Dubai.

For historical reasons, the United Business Media group’s parent company has been tax resident in the UK. However UBM has been progressively disposing of its UK media businesses, including the Anglia, HTV, Meridian and Channel 5 television franchises, Express Newspapers, NOP market research and Exchange & Mart.

"Consequently, the Board of UBM now believes that the long term interests of UBM and its Shareholders are best served by the adoption of an international holding company corporate structure that domiciles UBM’s parent company in the Republic of Ireland, which has a less complex system of taxation," the company's statement explained.

It continued: "In contrast, the UK tax system imposes tax on all companies in a worldwide group, and consequently UBM has had to manage the interaction between the UK tax system and the tax systems of the multiple countries in which UBM operates. This has given rise to both significant compliance costs and risks of inadvertent tax charges arising."

If approved by shareholders, the new structure is expected to become effective on 30th June, 2008. The restructured UBM group will have the same board and management team, and will be listed on the London Stock Exchange (LSE).

A comprehensive report in our Intelligence Report series looking at offshore and onshore corporate structures and their tax implications is available in the Lowtax Library at http://www.lowtaxlibrary.com/asp/subs_reports.asp and a description of the report can be seen at http://www.lowtaxlibrary.com/asp/description_report7.asp

 


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