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Accenture Shifts Tax Base To Ireland,
by Mike Godfrey, Tax-News.com, Washington
Monday, June 01, 2009
Consulting firm Accenture has announced that its board has unanimously approved
changing the company’s place of incorporation to Ireland from Bermuda.
The company announced that shareholders will be asked to vote for the proposed
move at meetings expected to be held within the next three to four months.
William D. Green, Accenture’s chairman & CEO, said: “After
a careful review, our Board of Directors has determined that changing our place
of incorporation to Ireland is in the best interests of Accenture and our shareholders.
We believe that incorporating in Ireland will provide Accenture with economic
benefits and help ensure our continued global competitiveness."
Accenture, formerly known as Anderson Consulting, was embroiled in controversy
in 2004 when the United States Congress attempted to block firms incorporated
offshore from bidding for US government contracts. At the time, the firm was
attempting to secure a Homeland Security contract to administer the US Visitor
and Immigrant Status Indicator Technology (US VISIT) program, worth USD10bn.
According to the Wall Street Journal, the company’s regulatory filing
disclosing the planned reincorporation cited legislative proposals announced recently by the Obama
administration, which would treat companies incorporated offshore but
effectively managed and controlled in the US as domestic entities for tax purposes, as a motivating factor.
Accenture’s chief executive is currently based in Boston, Massachusetts,
while its operating office is located in Austin, Texas.
However, Accenture’s press release listed Ireland’s membership
of the European Union, its network of tax treaties with the US, EU member states
and other countries and its “sophisticated, well-developed corporate,
legal and regulatory environment” as the reasons for moving its place
of incorporation there.
“It also has a long history of international investment and long-established
commercial relationships,” the company stated. “In addition, Ireland
offers a stable political and economic environment and has the financial and
legal infrastructure to meet Accenture’s needs, both today and in the
future.”
While Ireland’s rate of corporate tax, at 12.5%, is low by global standards,
corporate tax in Bermuda is 0%. However, because the latter jurisdiction does
not impose tax, by definition it has not entered into any double taxation avoidance
treaties, although it has Tax and Information Exchange Agreements with the
US, UK and Australia, and is concluding TIEAs with several other countries in
order to meet the new OECD on tax transparency.
The company also stated that Ireland is in a region which accounts for nearly
half of Accenture’s total net revenues, is home to many of the company’s
largest clients and represents “a significant business opportunity for
the company.”
“Today the company serves a wide range of clients in the country, including
the Irish government, and has significant operations and a substantial presence
there that has grown rapidly in recent years,” the company explained.
Accenture stated that it does not expect any material change in its operations,
financial results or tax treatment as a result of the change in its place of
incorporation.
If the proposal receives shareholder and regulatory approval then Accenture
plc, an Irish company, will replace Accenture Ltd as Accenture’s parent
company.
A comprehensive report in our Intelligence Report series,
titled "Offshore For Corporates", discusses in depth the comparative
merits of offshore HQs, with a Corporate Treasury section analysing how to get
an optimal blend of tax-efficiency and profits and finally a study into how
two types of international business can use onshore low-tax regimes in parallel
with offshore jurisdictions to construct highly tax-efficient corporate structures,
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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