Multinationals fret over ruling on intellectual property sale

Ireland’s American business community was strangely quiet yesterday. And it was not entirely because they were keeping close tabs on the see-saw count in the US presidential election. There was also a pressing local issue.

Perrigo, a relatively low-profile over the counter medications firm, has found itself in the spotlight over how it accounted for the tax treatment of intellectual property (IP) for a multiple sclerosis drug, Tysabri, sold by Irish pharma Elan months before Perrigo bought the company.

It said the sale was normal business and applied a 12.5 per cent corporation tax rate; the Revenue Commissioners argue it should be seen as a capital gain, taxed at 33 per cent. At issue is a Revenue bill for €1.64 billion, the second largest assessment levied in Ireland to date.

The onshoring of IP in Ireland by US multinationals has been a key element in the surge of corporation tax

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