Confused about Ltd's as part of multi-nationals

sopretty

Ok, I probably need someone with a bit of knowledge of how multinationals operate to answer this question.

I'm doing an assignment and am somewhat confused to say the least.........

I have to introduce the company in the assignment which I did as follows:

" Polkadots Ireland Limited is a Private Limited Company operating in Dublin for over 30 years (having undergone several mergers and changes in management over the years). It is a manufacturing plant for highly engineered x's for use in xy&z. In some cases products may be sold as a finished product to the End User or while in other cases the products will be sold inter-company to other Polkadots manufacturing plants to be used as part of a larger product which is then sold onto the end user. Polkadots Ireland Limited, though a business entity in its own right is also a division of a larger publicly floated company, head-quarters of which is based in Orlando, Florida with over 300 locations worldwide. Ireland was chosen for its low corporate tax rate and also as an entry into the EU market. The Irish plant has proved to be extremely successful and profitable.


Now, I sent this to a manager within Polkadots Irl. Ltd. and he has said that it is

" An American Multinational Limited Company (Headquartered in Orlando, Florida and publicaly floated on the NYSE trading under the name of PAM)"



So, I have replied to him with the following question, which perhaps some of you more knowledgeable folk may be able to answer:

" So then it's not a business entity in its own right benefiting from our low corp tax rates? It's just a division of an American Limited co., though floated on the NYSE? Forgive my ignorance, but I thought it couldn't be a private limited company AND floated on the SE?

I'm more confused than ever now lol!"
Can anyone enlighten my mithered brain?

Obviously, company names and locations have been changed, just in case you all start trying to buy shares in PAM..........


Having done more digging on cro.ie, Polkadots Ireland Limited (or the real name) is not registered in Ireland. I'm just wondering how it works, who Polkadots Ireland Limited pays taxes to and why they chose Ireland? If you get me? Because, if they're not registered as a company in Ireland, why Ireland? Confused.com

Can anyone help me with figuring out how Ltd.'s in Ireland operate in terms of taxes etc. within a publicly floated company?

srsly78

There is an IRISH company called Polkadota Ireland limited. This is 100% owned by the publicly quoted AMERICAN company.

The irish subsidiary operates just like any other irish limited company. They pay the same tax etc. The only difference will likely be a big charge levied by the parent, this charge will probably reduce any profit to zero - therefore very little corp tax to pay. The parent can arbitrarily charge the subsidiary one meeeelion dollars for worthless widgets and the subsidiary can agree.

Where various tricks come into play is when the parent bills the subsidiary for royalties rather than physical goods. These get treated differently, and various loopholes can be explioted. http://en.wikipedia.org/wiki/Double_Irish_arrangement

If you still aren't confused then consider this: The Irish subsidiary could be owned by the parent, which could be in turn owned by another Irish company, which is also owned by a multinational.... repeat ad infinitum.

sopretty

Polkadots/Polkadota Ireland Limited is an entirely fictional name I made up! I can send you a private message with the real name?

srsly78

Why? Noone is really that curious. You will find crazy ownership arrangements behind almost any company you care to query.

www.duedil.com - this is a good site for looking up company info for free

sopretty

Or were you giving me the answer using my fictional name as an e.g. as to how it works?

srsly78

I see you are quite an astute poster.

sopretty

I am interested, as I have to do an assignment on them.

srsly78

Go use the website I linked, start looking at their accounts. Also find out who owns the shares and then lookup the Directors etc.

All Irish private limited companies are obliged to file accounts.

sopretty

srsly78 wrote: »

I see you are quite an astute poster.

I can see you are not taking me seriously. I'm confused, just looking to try to understand. And to make sure the information I present is correct.

srsly78

Please refer to previous post.

sopretty

My question really is, is whether this statement is factual:

"Polkadots Ireland Limited, though a business entity in its own right is also a division of a larger publicly floated company, head-quarters of which is based in Orlando, Florida with over 300 locations worldwide. Ireland was chosen for its low corporate tax rate and also as an entry into the EU market. "

srsly78

If you follow the instructions in post #8 you can check facts for yourself.

sopretty

I referred to your previous post and web address which requires registration and I thought someone might just be able to give me a quick and simple answer. If it requires digging, I'll dig. Problem is, this is worth 1% of my entire module and really, if I get it wrong, nobody is probably going to know anyway, but my nose is at me now! So I want to know, outside of the assignment!. Curiosity killing the cat/assignment etc.

srsly78

Yes it requires free registration. Just do it, the alternatives involve paying the CRO real money to look at these documents. It takes 15 seconds to register, then you can query company and director records for any company in the UK or Ireland.

This IS the quick and simple answer. 30 seconds of research and you can veryify who owns this limited company.

sopretty

But if it is not registered on www.cro.ie then how can I look up its accounts?

sopretty

I already know who owns the bloody company!

sopretty

What I want to know is who they pay taxes to and if they don't benefit from our low corp tax rate, why did they choose Ireland????????

srsly78

Because of transfer pricing, read the previous links.

If they are not registered with CRO then they are not a private limited company. Are you sure they are not a private unlimited company? This would mean lots of stuff would remain hidden.

For a normal private limited company tho you should be able to find all their details on that website.

sopretty

Ok, it is listed on your recommended website but doesn't give me any information. Well, none that I need anyway. It doesn't say who owns it.

srsly78

Is it an unlimited company? If so then it doesn't have to make it's accounts public. Is it newly formed? The various websites will only show you accounts from last year. There will be no info available for a new company.

sopretty

Ok, I'm first year in a Business degree. So go easy on me. They are apparently an Irish Limited company. From your recommended website, there are details of them there. But there are no details of them on www.cro.ie. Maybe I should choose a different company to write about. You're about to make me cry lol!

srsly78

If you can't find them on www.cro.ie then something is very messed up, most likely you are spelling it incorrectly or other similar mistake.

sopretty

'Most likely your spelling it incorrectly'????????
I can assure you I am not.
Although you could do with a refresher on the difference between 'your' and 'you're':rolleyes:

sopretty

Good edit there genius.
You have been most unhelpful.

sopretty

Ok, after some digging by someone who is better with a spade or shovel than I am it appears that they are a 1 shareholder private limited company.
I'm changing company for this assignment lol.

barneystinson

sopretty wrote: »

Ok, after some digging by someone who is better with a spade or shovel than I am it appears that they are a 1 shareholder private limited company.
I'm changing company for this assignment lol.

Why change? Surely that structure is consistent with your original statement - assuming you can confirm that the single shareholder is the US MNC...

sopretty

For 1% of one module out of 8?

I'll make it a hobby lol.

Between my finger and my thumb
The squat pen rests.
I’ll dig with it.

For the sake of this assignment??? Find a simple company, find a simple company, find a simple company.......

sopretty

Btw - I should thank you for your help and input. Genuinely thank you. Couldn't figure the whole thing out. Now I know it's not that I'm simple (though you may disagree), but that it's complex.

srsly78

Usually when I lookup a company with that site I can instantly see who owns the shares. I'd say just try another company and you will have better luck.

sopretty

The one found on solocheck.ie or something or another is a new company set up by them. The BIG company. Nothing seems to be available on what 'sounds' like a private limited Irish company i.e. the one I was working with. My brain is going into girl overload. So I'll stick with the partnership that went out of business while I worked there....

sopretty

Just to clarify - the only company that could be found bearing a similar name is owned by 1 shareholder. The company I worked for can not be found. I emailed one of the managers in Polkadots Irl. Ltd. and he said, no that is a new company set up by THEM. Edited to add - THEM being the big boys.
Quite bizarre.

srsly78

If it's new that's why you can't find much info on websites about them. Would have to go into CRO and pay money to actually see the paper records.

sopretty

I'll do a thesis on them if I get that far. For now,,,,,, 'find a happy simple place'.......

sopretty

Also, as far as I know, the company still exists as Polkadots Irl. Ltd. but is just not listed anywhere. Have they somehow managed to set up a sort of holding company with this new company name with PIL as a subsidiary and what benefit would that be to them?
I'm sure it's of benefit as the top holding company in the maze made 8bn profit last year. So they're doing something right.

sopretty

The company is 35 years in operation in Ireland, in the same place, with various mergers/acquisitions/takeovers/name changes. The company name as it exists now can not be found, only this new 'entity' name which has been set up very recently.

sopretty

Also, if it's new, I should be able to find 2010 or 2011 accounts?

srsly78

It would have to be 2-3 years old to have accounts from then, so it depends on your definition of new. Most companies have just now filed their 2012 accounts, and these are not visible online yet.

sopretty

Doesn't really apply to my definition of new, but their definition of new. Going by their definition of new I'd say the past 6 months at a max

srsly78

Find out what company they were trading as before, then you should be able to look at some accounts.

sopretty

Are you interested enough to do a bit of rooting if I give you the name via pm? Purely out of curiosity and purely because I lack the know-how...?

sopretty

They are still trading as the name I worked for.

srsly78

Ok I should have phrased that differently. Find out their official company name they used in the past, and their company number if possible. This should be written down on their company letterheads on any old documents. Companies leave a massive papertrail behind, and by law a lot of this is public information. The various company records websites just makes this easier to get.

sopretty

How do I send a pm?

sopretty

I 'think' I sent you a pm, but I can't find it.. Let me know if you did or did not get it.

sopretty

I'm just not going to do them. They confuse me. You confuse me.

sopretty

So, in answer to my original post, are they an actual stand-alone entity enjoying our corporate tax rate or not?

thecommander

sopretty wrote: »

So, in answer to my original post, are they an actual stand-alone entity enjoying our corporate tax rate or not?

You've given no information, so how can anyone answer.

Peterdalkey

This thread probably makes most sense when LSD assisted!

sopretty

Peterdalkey wrote: »

This thread probably makes most sense when LSD assisted!

Lol.
I have been pm'ing another poster who has been extremely helpful with the information, though he refused to spoon-feed me :mad:. I was basically confused as to how the manager described it compared to how I understood it. I was confused as to how Ltd.'s can be part of floated companies. I was confused about corporate tax rates. I was confused as it had one shareholder, as I stupidly thought that if a company had a shareholder then they couldn't be an ltd. I have since found the company. It is a limited company, with a holding company in Luxembourg which is in turn owned by the HQ company in Houston Texas. Perhaps I should change my name to 'dopey'.
Anyway, I have learned a lot in the past couple of days, so it's not all bad! Apart from discovering how little I know!!

sopretty

I've also discovered that whenever I have a few spare quid, they might be a good investment..... :cool:

sopretty

Also, in my defence, I am three weeks into a Fetac level 6 Business course. The last time I studied business was in Junior Cert - 19 years ago - I did 3 sciences to LC and no business subject... So apologies for my stupidity.