sunday tribune logo
 
go button spacer This Issue spacer spacer Archive spacer

In This Issue title image
spacer
News   spacer
spacer
spacer
Sport   spacer
spacer
spacer
Business   spacer
spacer
spacer
Property   spacer
spacer
spacer
Tribune Review   spacer
spacer
spacer
Tribune Magazine   spacer
spacer

 

spacer
Tribune Archive
spacer

Dell liquidates Irish firms in 'internal restructuring'
Ken Griffin

 


COMPUTER-manufacturing giant Dell liquidated Irish-registered companies with assets of over $10.5bn ( 7.9bn) in what the company termed "some internal restructuring" last December.

The company refused to comment on whether the assets were moved outside Ireland, but tax experts have suggested that it may have transferred them to the Netherlands, which introduced aggressive new tax laws at the start of this year.

International tax expert Richard Murphy, director of British-based consultancy Tax Research, said that Dell's actions proved that "tax competition doesn't work in the long term", particularly as the largest Dell subsidiary involved had an effective tax rate of 4.3%.

The company, the Irish branch of Dell Products (Europe) BV, made pre-tax profits of $780m ( 590m) in the year to 28 January, 2005, the final period for which accounts are available.

Its tax bill, however, was significantly reduced by government manufacturing relief. The firm, which had assets worth $10.7bn ( 8bn), was closed on 31 December.

The second major Dell subsidiary involved, Dell Computer, made pre-tax profits of $4.3m ( 3.2m) but paid only $284,783 ( 214,000) in tax due to government manufacturing relief. This meant it had an effective tax rate of 6.6%.

Dell placed the company in voluntary liquidation at the end of last December, along with another smaller company, Dell Financial Services International.

In the same month, Dell also notified the Irish companies registration office that it had redeemed $250m ( 188m) worth of shares from a fourth Irish company, Dell International Holdings XI, an investment vehicle, which does not have to file public accounts as it is an unlimited company.

One Dell subsidiary that escaped liquidation was Dell Research, a firm that collects patent royalties, which are not taxed under Irish legislation.

It made a tax-free profit of almost $25m ( 18.8m) in the year to 28 January, 2005.

Dell is the latest in a series of multinational companies that have liquidated or dissolved Irish companies in recent months.

According to Murphy, these moves have largely been tax driven and have been inspired by a predatory corporate tax regimes recently introduced by several countries, including the Netherlands, which are "worrying treasuries throughout the EU".

"I have little doubt that this is the reason why people are leaving Ireland. The problem Ireland faces now is that it has become used to getting a certain amount of corporate tax from these companies and they are pulling out, " he said.

However, a spokeswoman for Dell said that the moves were solely designed to simplify Dell's corporate structure in Ireland.

"They have absolutely no impact on Dell's operations in either Limerick or Cherrywood in Dublin. Dell remains fully committed to its Irish operations, " she said.

She refused, however, to comment on whether Dell had transferred the defunct companies' assets outside Ireland. "Details relating to the internal transfer of corporate assets and the specific tax affairs of Dell are commercially sensitive and therefore no further information is available on these matters."

The Department of Finance said that it was unconcerned by the move and denied that the recent wave of asset transfers showed that multinationals viewed Ireland as a tax haven.

"Ireland is not a tax haven and could never be viewed as such.

"We charge positive rates of tax, our corporate tax system brings in approximately 15% of our tax revenue, we have full exchange of information with other tax authorities and we have a network of double taxation treaties, " said a spokesman.

Coca-Cola, Cable & Wireless, Pepsi, Pfizer, Holcim, Banco Santander and Bristol-Myers Squibb are among some of the leading multinationals that have liquidated Irish companies in the past six months.




Back To Top >>


spacer

 

         
spacer
contact icon Contact
spacer spacer
home icon Home
spacer spacer
search icon Search


advertisment




 

   
  Contact Us spacer Terms & Conditions spacer Copyright Notice spacer 2007 Archive spacer 2006 Archive