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Barclays' taxing question

Robert Peston | 19:58 UK time, Tuesday, 20 March 2007

So what kind of an animal would the combined Barclays and ABN turn out to be? A slightly strange hybrid, based on the information Barclays put out this afternoon.

It would be incorporated in the UK with a primary listing on the London Stock Exchange. But its head office would be in Amsterdam.

Meanwhile its operational centre would be in London. However it wants its primary regulator to be the Dutch Central Bank (though that may not be achievable, if the US regulator were to insist – as it might – that London’s Financial Services Authority should be the lead regulator).

As for management, the first chief executive would be Barclays’ John Varley, while ABN AMRO would supply the first chairman.

For shareholders, the most important – and welcome – decision taken by the two banks so far is that the new entity would have a single board, along British lines, and unambiguous management and governance structures. It looks as though the danger has been averted that Barclays/ABN would be a messy, multi-layered, multi-listed monster with no one properly in charge.

But for the Chancellor on the eve of his last budget, there is one rather worrying uncertainty created by the deal: it’s by no means clear whether it’ll pay tax primarily in the UK or in the Netherlands.

There would be clear advantages to being registered as Dutch for tax purposes. Why? Because there are more favourable arrangements in the Netherlands for offsetting tax paid on overseas earnings against the local liability than we have here in the UK.

That’s why, for example, Shell decided to have its tax domicile in the Netherlands when it opted for a unitary structure.

So for all Barclays saying that the tax-domicile decision hasn’t been taken, my tax-specialist chums tell me it’s a racing certainty the Netherlands will be the winner.

What does that mean? Well it probably wouldn’t lead to a loss to the British Exchequer immediately. Tax payable on UK earnings and incrementally on profits from its current overseas operations would still flow to the UK.

But it means that the UK wouldn’t benefit as and when the enlarged group established new operations in fast growing parts of the world like India and China. Profits repatriated from such new territories would go to the Netherlands, and would be taxable in the Netherlands, not the UK.

Over the long term therefore there would be a serious cost to the UK. Should we blame Barclays for being ambitious and wanting to create a world-leading global bank – and being prepared to compromise to achieve that ambition?

Or should we blame the Chancellor for putting in place tax arrangements for multinationals that are uncompetitive with those of the Netherlands?

As it happens, it’s a funny old time for this unseemly tax question to be raised – because my understanding is that much of tomorrow’s budget will be aimed at restoring the competitive of the UK’s corporate tax regime. Barclays will be crossing fingers and toes.

°ä´Ç³¾³¾±ð²Ô³Ù²õÌýÌý Post your comment

  • 1.
  • At 03:21 PM on 22 Mar 2007,
  • john dolder wrote:

After an early retirement @62 I have a pension of just over £9000, on todays threshholds i will be paying an additional £176 pa tax after the 10p rate is abolished and the new rate reduced to 20p.
Where do the Tax SAVINGS come in?
Many pensioners must be in the same income bracket and be in a simular situation.
So the less paid will be hit hardest, and a hugh increase in the lower tax threshhold to about £13,000 (from £5035)would be needed to counter this 10p level being removed.I don't think this will happen will it Gordon?

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