Comment: Far from representing the lack of economic patriotism of US companies, the trend of inversions out of the US is indicative of just how antiquated the US tax code is.
A Swedish committee on corporate taxation has proposed reforms to limit interest deductibility in the country. Borje Noring, tax auditor at the Swedish Tax Agency, Skatteverket, reacts to the proposals, which have drawn criticism from US business representative groups.
Between 1983 and 2004 there were 29 inversion transactions out of the US. In the decade following, almost 50 companies restructured using the method. With foreign profits trapped offshore by an outdated, worldwide system which would hit them with a tax on repatriation, as well as a high tax rate, the temptation to consider an inversion is proving too much for US companies, particularly those in the highly-mobile pharmaceuticals sector. Whatever the motivation, inversions are in vogue. ITR’s special report looks at the knock-on impacts of the current wave of inversions, including shareholder pressure to consider an option they see their rivals pursuing and the possible inflammation of the tax morality debate in the US. We also bring you exclusive insight as to why Danaher is not looking to invert.
In part two of International Tax Review’s exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in the Netherlands, discusses the transition from adviser to in-house professional, analyses the challenges an in-house tax team faces, and stresses the importance of thinking divergently to find creative solutions.
After the failure of the Pfizer-AstraZeneca transaction at the end of May, the two companies have now announced new deals with other companies. But the two drugs companies could return to the proposed inversion deal later this year.
The Senate Finance Committee this week held a hearing on proposals to reform the taxation of multinational enterprises, and given the recent trend of US companies inverting abroad, the hearing unsurprisingly focused on dealing with inversions.
