This could also explain why a move to The UK is important to NWBO - 'Inversion'. When the production of all the vaccine increases to such high volume, we will be talking about $100k per treatment PLUS. So, why would LP want to pay exorbitant TAX rates in the U.S. and Maryland? Maybe I'm off base with a full explanation, but I think it may contribute to further the conversation along, maybe?
WHY IRELAND?
Ireland is not the only home for inversions Britain, the Netherlands and Switzerland are also popular. Pfizer made a $118 billion bid to buy AstraZeneca Plc <AZN.L> this year, so it could move its tax domicile to Britain, but the pharmaceutical giant was rebuffed by its target.
But for tiny Ireland, the deals can be vast, such as Medtronic's <MDT.N> $42.9 billion takeover of Irish-domiciled Covidien <COV.N>, which led to a near sixfold rise in the value of Irish-based M&A in the first half of the year - and almost 20 percent of all of Europe's, research by information services company Experian found this month. [ID:nL6N0PK4JL]
It is not just tax that encourages inversions from the United States to Ireland.
Ireland's Arthur Cox, legal advisers on deals worth 56 billion euros this year, according to Experian, lists the attractions of a legal system similar to the United States', no shareholder rights to interfere with executives' pay and limited rules on the "transfer pricing" of intercompany transactions, which can also be used to shift profits to avoid tax.
"If you look at what Jazz Pharmaceuticals <JAZZ.O> have done (after buying Ireland's Azur Pharma in 2011), they're actually building a center. That's the type of thing that will strengthen the case for inversions - real employees, bricks and mortar."
"SLIPPERY SLOPE"
One Dublin-based M&A banker, who declined to be named, said Ireland's Office of the Revenue Commissioners, which assesses and collects taxes, has been on red alert since late last year around any sort of structure or deal that might be seen as trying to evade tax.
"It would be a lot harder for an overseas company to set up in Ireland now versus even two years ago unless they were bringing a large number of jobs with them," he said. "They are not as forthcoming or facilitative as they used to be."
A spokeswoman for the Commissioners said they are always on the lookout for such structures and apply the relevant legislation fairly to all entities tax resident in Ireland.
"What companies want is certainty. When we visit firms in the States and elsewhere, they mightn't always be able to find Ireland on a map, but the 12.5 percent rate is nearly a mantra," Dillon Eustace's Tiernan said.
News 
Market Data 
Discover 
