Here ya go skull. Why Pfizer moved.
At the centre of Pfizer’s decision to move its tax base is the distinctive US system of worldwide taxation, which means that companies pay extra tax when they repatriate foreign profits, giving them an incentive to leave them offshore. The inversion will help Pfizer unlock offshore profits of at least $128bn, potentially saving tens of billions of dollars of tax.
Ireland’s system — where tax is due only on business conducted in the country — means Pfizer would not face any extra tax bills on its foreign profits in the future. Any extra tax paid at Ireland’s 12.5 per cent rate would depend on whether the tie-up resulted in extra activity in Ireland, where Pfizer will have its principal executive office. Its global operational headquarters will be in New York.
The company has $74bn of foreign profits that are deemed to be “permanently reinvested” overseas, on which it has not earmarked deferred tax. It has another pot of profits — worth at least $54bn — on which it has earmarked $21bn of “deferred” tax in case it needed to bring the money back to the US.
The merger with Allergan will allow Pfizer to scrap this $21bn deferred tax liability, creating a one-off boost to its earnings. Kevin Phillips of Moore Stephens, a professional services firm, said: “The challenge would be to secure this benefit without also crystallising a taxable gain in the US as Pfizer transferred its foreign subsidiaries into the ownership of its new holding company.”