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Published by:
Stanford Business School (2018)
Version:
1 May 2017
Revision date:
02-Feb-2018
Length:
31 pages
Data source:
Published sources

Abstract

In November 2015, US-based biopharmaceuticals company Pfizer [NYSE: PFE] and Ireland-based pharmaceutical company Allergan [NYSE: AGN] announced a USD160 billion merger to move Pfizer's domicile out of the United States to Ireland in the largest inversion deal ever. The announcement came just days after the US. Treasury Department laid out a set of restrictions on tax inversions; however, the deal was structured to avoid those restrictions. According to the US Department of the Treasury, 'By undertaking an inversion transaction, companies move their tax residence overseas to avoid US taxes without making significant changes in their business operations.' Two primary benefits provided by inversions were: (1) the removal of a company's foreign operations and income from the US taxing jurisdiction to achieve pure 'territorial' tax treatment (in which income was taxed only in the country where it was earned); and (2) the reduction of US taxes on income from US operations through the use of various 'earnings stripping strategies' (eg, making payments of deductible interest or royalties from the US entity to a new foreign parent). According to Reed College economist Kim Clausing, inversions and other income-shifting techniques reduced Treasury revenues by as much as USD111 billion in 2012.

Topics

Accounting; Tax accounting; Corporate tax; Deferred taxes; Effective tax rate; Statutory tax rate; Taxation; Mergers & acquisitions; International mergers; Mergers
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2017

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