Two tax deductions — One interest payment

$140m

interest

payment

AZ offices in the

Netherlands

AZ offices

in the UK

The outcome

Two tax deductions on the same payment by the same Dutch co-op. One in the UK, one in the Netherlands. Here’s how

 

What do

the Dutch see?

Dutch co-ops are well known. they are like other taxable companies in the Netherlands. There is no need to worry about the tax affairs of the co-op’s owner. Any interest costs are treated as borne by the co-op in the Netherlands

 

Tax result

The interest payment by AZ Co-op creates a Dutch tax deduction that the group can use to lower its Dutch tax bill

What does

the UK see?

Dutch co-ops are unfamiliar. Instead of grappling with how to treat them, co-ops are classified as 'transparent' by the UK. That means costs incurred by AZ Co-op are treated as if they were costs borne by the co-op's owner, which is AstraZeneca in the UK

 

Tax result

The interest payment by AZ Co-op creates a UK tax deduction for its owners that the drugs group is able to use to lower its UK tax bill

 

AZ

Co-op

$140m

interest

payment

AZ offices in the

Netherlands

AZ offices in the UK

What do the Dutch see?

Dutch co-ops are well known. they are like other taxable companies in the Netherlands. There is no need to worry about the tax affairs of the co-op’s owner. Any interest costs are treated as borne by the co-op in the Netherlands

 

Tax result

The interest payment by AZ Co-op creates a Dutch tax deduction that the group can use to lower its Dutch tax bill

The outcome

Two tax deductions on the same payment by the same Dutch co-op. One in the UK, one in the Netherlands. Here’s how

 

What does the UK see?

Dutch co-ops are unfamiliar. Instead of grappling with how to treat them, co-ops are classified as 'transparent' by the UK. That means costs incurred by AZ Co-op are treated as if they were costs borne by the co-op's owner, which is AstraZeneca in the UK

 

Tax result

The interest payment by AZ Co-op creates a UK tax deduction for its owners that the drugs group is able to use to lower its UK tax bill

 

AZ Co-op

Netherlands

$140m

interest

payment

AZ offices in the

Netherlands

AZ offices in the UK

What do the Dutch see?

Dutch co-ops are well known. they are like other taxable companies in the Netherlands. There is no need to worry about the tax affairs of the co-op’s owner. Any interest costs are treated as borne by the co-op in the Netherlands

 

Tax result

The interest payment by AZ Co-op creates a Dutch tax deduction that the group can use to lower its Dutch tax bill

The outcome

Two tax deductions on the same payment by the same Dutch co-op. One in the UK, one in the Netherlands. Here’s how

 

What does the UK see?

Dutch co-ops are unfamiliar. Instead of grappling with how to treat them, co-ops are classified as 'transparent' by the UK. That means costs incurred by AZ Co-op are treated as if they were costs borne by the co-op's owner, which is AstraZeneca in the UK

 

Tax result

The interest payment by AZ Co-op creates a UK tax deduction for its owners that the drugs group is able to use to lower its UK tax bill

 

AZ Co-op

Netherlands