Category Archives: income shifting

Tax Shifting Update: January 2019

Government will fight to support Apple, but Perrigo must battle alone- by Cliff Taylor, The Irish Times

Key Takeaways: 

  • The Irish government will help Apple (AAPL) defend again an EU claim of €14 billion in taxes while Perrigo (PRGO) will not get support for €1.64 billion sought by the Irish Revenue office.
  • With 2017 revenue at $229 billion at Apple and $4.946 billion at Perrigo, the claim against Apple is only 6.11% of 2017 revenue while the claim against Perrigo is 33.15% of 2017 revenue.
  • Apple doesn’t need the help of the Irish authority but will get it, Perrigo needs the help of the Irish authority but won’t get it.
  • This is a classic catch-22, if the Irish Revenue agency wins their case of taxes owed by Perrigo then it will legitimize the EU’s claim against Apple.  The Irish Government wants what is owed to it but does not want its biggest client to lose a case that marginally affects its bottom line.
  • The expected outcome of either case is tentatively slated for two years after the initial claim.
  • We suspect that the implications of the Perrigo case will dawn on the Irish Revenue Authority and they will settle for far less than what was initially sought and it will be deemed a victory on all sides.

Retrospective: Bristol-Myers pulls $25 bln assets out of Ireland by Matthew Tostevin, Reuters March 16, 2007

Key Takeaways:

  • Bristol-Myers Squibb (BMY) pulled $25 billion out of Ireland in March 2007.
  • “It’s a holding company. It does not have any business operations or workforce,” said Brian Henry.
  • “Henry declined to comment on a report in The Irish Times that the move was to benefit from even lower corporate tax rates elsewhere…”
  • The performance of BMY stock price after the shifting of $25 billion out of Ireland coincides, but not necessarily caused by, with a peak and subsequent decline of -34.71%.

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