Fiat Industrial is planning to transfer its tax residence from Italy to the United Kingdom after it consummates its planned merger with unit CNH, according to a filing with US regulators. According to its financial accounts, Fiat Industrial paid EUR536 million ($689 million) in taxes in 2012 at an effective rate of 36 percent, plus a EUR28 million payment for a regional tax -- on a net profit of EUR921 million.
The move will allow Fiat Industrial to lower its tax bills, as the UK is cutting its corporate tax rate from 30 percent in 2007 to 20 percent in 2015. Additionally, the UK relaxed its "controlled foreign company" tax rules from the start of 2012 to entice companies to transfer their headquarters to the country. Under the new rules, companies could only be taxed on profits generated in the UK and not on profits earned abroad.
The UK government has been critical of international companies that earns billions of pounds in the country, but pay little tax since they are based overseas. Fiat Industrial is planning to merge with CNH, and then collapse both companies into a new group initially called FI CBM Holdings NV, with a primary listing on the New York Stock Exchange.
Fiat Industrial filed a preliminary prospectus on May 14, 2013, and expects the merger and listing to be completed in the third quarter of the year. Italian carmaker Fiat, Fiat Industrial's sister company, is also considering a US listing after it completes a merger with US automaker Chrysler.