The Revenue Commissioners are reviewing the international corporate structures used by Larry Goodman's ABP Food Group and other businesses, in the light of details made public last month.
The move comes in the wake of reports in this newspaper about group companies based in Luxembourg, the accounts of which show massive inter-group loans and dividend payments that are only lightly taxed. A company called Parlesse Investments Sarl has booked profits of approximately €280 million between 2010 and March 2013, and paid tax of approximately €800,000.
The company, which is owned by a company in Malta, makes its profits from interest payments and dividends and is structured so that the profits are largely untaxed under Luxembourg’s tax rules.
Mr Goodman is a former director of the company. The interest payments and dividends come from other group companies and the Revenue is now examining the structure to see whether it has any possible tax implications in this jurisdiction.
ABP Food Group is headquartered in Ardee, Co Louth, but is owned by way of a complex network of companies that include Parlesse and companies in Jersey, the Netherlands, and elsewhere. The disclosures about Parlesse , the accounts of which are publicly available, were unusual in that his business affairs tend to be structured in ways that maintain a high degree of privacy.
In a letter published in The Irish Times today, Mr Goodman, in response to last month's disclosures, said the reports were damaging to ABP as they did not give a fair reflection of the taxes paid.
“The group, which is headquartered in Ireland and has successful operating plants in Ireland, Britain, Poland, the Netherlands, Denmark, Austria and Spain, pays substantial millions in corporation taxes on the profits earned and is tax compliant in all jurisdictions in which it operates,” he wrote.
Mr Goodman, who is executive chairman of the ABP group, also said, in a short statement issued last night, that he lives in Ireland, is a tax resident here, and is fully tax compliant.
The ABP group does not publish consolidated accounts, or accounts that give an overview as to the size and profitability of its overall business. The group is owned by way of unlimited companies in Ireland, which do not have to publish accounts, and companies in Jersey, where companies do not file detailed accounts.
The group structure also involves a foundation based in Liechtenstein. The structure and its filing practices are perfectly lawful.
