
The American medical equipment manufacturer Medtronics announced the desire to change the tax residence permit from the United States to Ireland, writes Bloomberg . This will become possible after the acquisition of a competitor, Covidien, an American company that changed tax citizenship to Irish back in 2009. The transaction is announced on the general website of two companies.
After a merger in the market, the largest manufacturer of medical equipment in the world with a staff of 87 thousand employees in 150 countries of the world will appear. The total income should amount to $ 27 billion. It is planned that the transaction will be closed in the IV quarter of 2014 or at the beginning of 2015.
Medtronic is in a conflict with the US tax department, the company has accumulated $ 20.5 billion profit in offshore subsidiaries. In 2010, the tax authorities ordered Medtronic to pay $ 958 additional taxes for 2005 and 2006. Covidien should also pay $ 914 million with offshore income for 1997-2000 plus $ 154 million. 19 out of 41 Covidien factories are located in the United States, most of the sales are coming here, the company is actually managed from the city of Mansfield in Massachusetts.
According to American laws, the profit that was obtained from foreign maternal companies, if the maternal - tax resident of the United States is also taxed, above those who “daughters” paid in their jurisdictions. Corporate tax in the USA is one of the highest in the world: 35%. That is why, writes Bloomberg, 44 companies have already changed tax citizenship, of which 14 have done this over the past year and a half.
In the spring of 2014, one of the world's largest pharmaceutical companies Pfizer announced the intention to switch to the jurisdiction of Great Britain. To do this, she filed a proposal for the merger against the British competitor Astrazeneca. Four times Pfizer offered an increasing price, up to $ 117 billion, but four times received a rejection of Astrazeneca management. Pfizer temporarily left the negotiations , leaving a proposal in force.
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