![]() ![]() ![]() Revenue took the view that it was a capital transaction, with any gains liable to be taxed at 33 per cent. This was in line with the way it treated previous such deals, Perrigo insisted. The problem was that Elan had accounted for the deal as the sale of intellectual property with the proceeds counting as trading income subject to corporation tax at 12 per cent. In many ways, Elan at that time would have been a better fit for patent revenue business Royalty Pharma, which Perrigo saw off to clinch the deal. Talking to Kessler, you suspect that selling point would put the Irish deal squarely in the category of "off-strategy" business moves that he was brought in to knock back into shape. This involved a foreign company, most often American, backing itself into an Irish business to avail of our lower corporate tax rate.Īlongside tax, a key attraction of the $8.6 billion deal was the stream of royalty income attached to Tysabri. The sale had taken place in 2013, before Perrigo even acquired what was left of Elan later that year in what was then a controversial practice known as corporate inversion. The bill dated back to the sale by an Irish pharma company called Elan of the rights to Tysabri, a multiple sclerosis treatment it had developed, to its partner in that drug, Biogen. “It was like I got my legs chopped out from under me,” Kessler recalled. ![]()
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