From the Courageous State

  1. 1.    Where to locate a head office.

This requires deciding in which country a head office will be located. Sometimes the decision relates to what are called ‘intermediate holding companies’ instead.

The importance of the decision is determined by the fact that a company usually has to pay tax in the country in which it incorporated. So, choosing to locate a company in a high tax territory such as the USA (which has amongst the highest corporate tax rates in the world) can be expensive[4]. However, quoted companies usually need to be incorporated in a major financial centre such as London, New York or Frankfurt. The result is that tax cannot be minimised in those locations.

Oh dear.

Absolutely no one incorporates in London or Frankfurt. They are not legal jurisdictions in which one can incorporate. England and Wales perhaps, Germany maybe, but not London or Frankfurt.

Further, you do not have to be incorporated in England And Wales to be listed in London.

US quoted companies are, almost without exception, incorporated in Delaware, not New York.

It\’s not looking good for the accuracy here, is it?

12 thoughts on “From the Courageous State”

  1. what we are waiting for is not this stuff, which everyone knows he will get wrong, but the stuff like…how many different definitions of “neo-liberal” are there in the book?

  2. Surreptitious Evil

    Oh, there won’t be any definitions – he doesn’t let him self be caught out by offering such hostages to fortune. There are quite likely to be many unrelated, often mutually exclusive, abuses of the term, however.

  3. Actually the vast majority of stock exchanges to do not require the vehicle to be incorporated in the jurisdiction of the exchange. Here are a few that don’t LSE, NYSE, HKSE, SGX. The most recent IPO was Glencore which was dual listed in London and Hong Kong using a Jersey holdco, sitting above the swiss company.

    Another moronic comment from a fool who knows little

  4. You’re just nit-picking Tim. You know what he meant. Can’t you come up with something better than this?

  5. This is the man that thinks that living and working and paying income taxes in a foreign country is avoiding UK tax. All bets are off at that point.

  6. Paul, it’s worse than that, he thinks that all ex pats with British citizenship should be paying UK income taxes.

    As a UK citizen working in CH, I take this kind of personally – paying UK income taxes on my income here would beggar me. He is, of course, rather thin on the details – would it be double taxation sang pur, or would you write off the CH taxes (and then only federal, or cantonal or council or what combination), or would there be an allowance? He doesn’t say… typical leftie he’s not using his brain.

  7. Mike: The London or Frankfurt thing might just be nit-picking (I don’t think it is, but you could make a case that it is). But the New York thing is a genuine and complete cock-up, because NY and DE will have some different rules, regulations, and local taxes. Why else would companies incorporate in DE and not NY?

  8. @Fred,

    It’s all right for you in CH (cue Pythonesque Yorkeshireman one-upmanship).

    Being a British “expat” living working and paying taxes in D, having to pay UK taxes on top of that would probably leave me with a negative income!

  9. Of course you can register in Frankfurt. Tim is plain wrong. Germany has a municipal system of registration rather than a national system. Just go to and you can see the full list of registry courts, town by town.

    It means you have to re-register the company if you relocate to another town, but then you have to change the car number plates too. A lot of things are more decentralised in Germany.

  10. Fred: I’m well aware Ritchie is a fuckwit, and I’m an expat who has no desire to pay UK tax on my income – but the US system is an obvious model of how it would be done, with foreign taxation written off and tax only paid on the difference.

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