Ritchie really doesn’t get tax, does he?

On AbbVie:

New profits can be earned from intellectual property rights located either here via the patent box or in low tax jurisdictions without ever having to worry that the UK might ever question the arrangements and the US has lost out on all the tax on unremitted profits denied to it for years.

Err, no. As I point out here that future revenue stream of corporate income tax that will not be paid is , to a greater or lesser extent, now capitalised into the stock price. And the merger is a taxable event for US shareholders. Meaning that the US will gain capital gains tax (and possibly income and corporate income tax) revenues from taxing the capitalisation of that future loss of corporate income tax.

Because there are many more taxes that the corporate income tax it simply isn’t true to insist that a reduction in corporate income tax revenues is the same as a loss of tax revenues in general.

6 thoughts on “Ritchie really doesn’t get tax, does he?”

  1. “Intellectual property rights located either here via the patent box. ..” ???????

    No, he doesn’t get tax either in the wider sense Tim means or in any narrower sense either.

    He also believes an accelerated payment notice requires you to change your self assessment.

  2. Yes it is Arnold, buy my opinion is the opinion of a tax professional. So I’ll have my opinion!

  3. Ritchie really doesn’t get tax, does he?

    No, but one thing he does get is drawing endless pictures of fvcking interlocking circles with meaningless text, questionable logic and calling them Venn diagrams

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