Any reason a corporation would want to move tax residency from Bermuda to Ireland?

[yehbut_nobut]

Bermuda - that was where Albert Reynolds once made an unscheduled stopover, wasn't it?

Ingersoll-Rand to move incorporation to Ireland

Associated Press, 03.05.09, 01:51 PM EST

Ingersoll-Rand Co. said Thursday that its board has approved the move of the company's incorporation to Ireland from Bermuda, citing its business operations in the European country and its strong business environment.

The move comes as other companies have recently pulled up stakes from the island nation and moved elsewhere amid an Obama administration crackdown on international companies that seek to avoid U.S. taxes by setting up shop in low-tax havens such as Bermuda.

Ingersoll-Rand (nyse: IR - news - people ), which makes refrigeration equipment and other industrial products, said it will establish tax residency in Ireland and then ask company shareholders to vote to approve the completion of the reorganization.
If the move is approved by shareholders and the [COLOR=#003399][FONT=Arial]Supreme
Court[/FONT][/COLOR] of Bermuda, Ingersoll-Rand plc, an Irish incorporated company, will replace Ingersoll-Rand Co. as the group's parent company.

Company officials said they chose Ireland because of its existing business activities there and the country's membership in the [COLOR=#003399][FONT=Arial]European Union[/FONT][/COLOR], along with its common law-based legal system and its stable business, legal and regulatory environment.

Do they read the papers?

[Mitsui]

Do they read the papers?

You mean all that stuff about lax corporate enforcement and legalised corruption and so on?

I daresay they do.

Why might that influence their decision?

[diablo]

Ireland isn't classified as a tax haven

Plus all the other reasons listed. EU membership and stability. Things might be tough but lets not get hysterical....we have a more stable business environment than all of Africa, most of Asia and Eastern europe

[He3]

They don't read the Irish Press anyways.

[yehbut_nobut]

Does this mean their profits will be taxed in Ireland? May not be such a bad thing if so. Seems they're not just here "on paper" - they have a manafacturing plant in Minister Fahey's Galway constituency, I beleive.


Edit: from last october's Irish Times

Union anger at €928m Thermo King dividend


Saturday, November 29, 2008
THE US-BASED parent of Galway refrigeration unit manufacturer Thermo King, which this week said it was laying off 110 workers, has taken dividend payments of €928 million from its Irish subsidiaries over the past two years.
Accounts just filed for Ingersoll Rand Irish Holdings, which wholly owns Thermo King, show it made a windfall payment of €878 million to its parent group last year and €50 million in 2006.
Much of this appears to relate to the €885 million sales of its Bobcat utility equipment business in July 2007, which netted the Irish company a profit of €730 million.
The Irish companies are owned by Ingersoll Rand, a commercial products manufacturer that employs 64,000 staff worldwide and has annual revenues of $8.8 billion. Listed on the New York Stock Exchange, Ingersoll is incorporated in Bermuda with its headquarters in New Jersey.

[islands]

Lots of holding companies are transferring to Ireland. As Diablo said, Ireland isn't classified as a tax haven (partly because the same low rate is charged to all companies), so firms here have access to a really wide range of international tax treaties and so on. also favourable treatment on intellectual property and patents

[cyberianpan]

Obama is stopping companies from going to "Unnatural" fake tax havens

Ingersoll-Rand obviously has "natural" business in Europe and thinks it can make case for a European tax base

Ireland at 12.5% is attractive

cYp

[Edo]

As the articles says - Obama is going to crack down massively on Tax havens and Bermuda is one of those - Ireland is the second tier so wont be hit for the moment - particularly if they have a manufacturing operation here.

But dont be so sure about the long term - if things keep getting bad or worse for us and we are on our knees to bailed out - Dont think that our Corporation Tax rate - which hurts countries like Germany,France and Italy - wont come up for some "Serious Discussion" when the lenders are laying down the terms of our bailout.

[Libernia]

Big operation in Swords. EMEA finance function or something like that. A natural relocation of their Corporate HQ in that case.

[Twin Towers]

Contrary to popular imagination Bermuda is a crime hellhole.