Now that Sergio Marchionne has succeeded in joining Fiat and Chrysler together, for his next act hes planning on moving Fiats headquarters out of Italy. While such a move has tax advantages, it would present a political and public relations challenge for Fiat and Marchionne in their home country. The new entity, dubbed
Fiat Chrysler Automobiles, will be a Dutch-based company with a UK tax domicile, while shares are listed on the NYSE with a secondary listing in Milan.
Marchionne is aware that locating the headquarters outside of Italy, where Fiat has operated for 115 years and has received government funding, or outside the United States, where
Chrysler was bailed out by the federal government, could make waves and there is the possibility that the Italian government might intervene. Ive seen weirder things happen, Marchionne said to journalists at the recent Detroit auto show. So I sincerely hope they dont create obstacles.
The deal for Fiat to take complete control of Chrysler after buying the UAW retiree health benefits trusts stake in the Auburn Hills based automaker was consummated last week and the result is the worlds 7th largest automaker, holding brands that include ,Alfa Romeo, Dodge, Ferrari, Jeep and Maserati along with the two corporate brands.
Marchionne is emulating what he did when he spun off CNH Industrial from Fiat: register the group in the Netherlands with a UK tax domicile. Marchionne has previously said that CNH Industrial will be used as one of the technical blueprints for Fiat-Chrysler. CNH is registered in the Netherlands, tax-resident in Britain and traded primarily on the New York Stock Exchange, with a secondary listing in Milan.
Chris Morgan, head of tax policy at KPMG, explained the reasoning. Where the actual production of cars is not carried out in the UK, the reason for coming here would be largely a tax one. Great Britain has had a series of cuts to its corporate income tax rate, and the government there is proposing to reduce it further to 20% next year. Britain has also reduced the tax burden on profits earned by foreign subsidiaries in low-tax jurisdictions. Also, unlike Italy, the UK does not tax dividends from foreign operations.
Marchionne, who trained as a tax accountant before attending law school by training, will present his plans to the Fiat board of directors today. Publicly he has insisted that moving the HQ and listing on the NYSE reflect access to funding more than tax considerations, saying that profits are taxed where they are made with no impact on the Italian governments tax revenue. Because of tax credits for previous years losses, Fiat will not have to pay domestic Italian taxes for years to come. Still, to reduce tax burden, manufacturers can adjust the amounts of total profit attributed to the production, export or sale of each vehicle in different countries.
For production staying in Italy they can reorganize the value chain to reduce the domestic tax burden, said Carlo Garbarino, a tax specialist at Milans Bocconi University.
The UK is now a good place to have the head office, KPMGs Morgan said. Any benefits you get from operating overseas in a low-tax country are not clawed back.
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