Source: Le Monde Diplomatique
SABMiller is one of the world’s leading beverage companies and a new report by ActionAid makes its history in apartheid South Africa of particular interest.
Among the strategies deployed by SABMiller during sanctions imposed on apartheid South Africa were ‘relocating’ intangible assets, such as the company’s many trademarks, to the Netherlands, a ‘conduit’ country used extensively for shifting corporate profits.
Not only did this allow SABMiller to bypass sanctions, but it also made it easier to expand into foreign markets – without the associated stigma of being an apartheid South African company – and avoid taxation through transfer (mis)pricing. The benefits of Dutch holding companies mean there is no requirement to have local economic substance, little or no taxation on repatriated profits, and full tax exemption on capital gains and dividends received from qualifying subsidiaries. And as ActionAid reports, according to Dutch law, the costs of acquired trademarks can be set against taxable income.