SAO PAULO, Brazil – JBS SA still plans to move its physical headquarters to Dublin, Ireland, but the company will be a tax resident in the United Kingdom.
Media reports said that Brazil’s federal tax authority placed Ireland on the country’s list of tax havens. As a result, companies will now be subject to a 25 percent Brazilian tax instead of the normal rate of 15 percent. Brazil defines tax havens as countries that are tax-free; have income taxes of less than 20 percent; and companies that don’t make their banking or trade information public.
In a regulatory filing with the Securities and Exchange Commission (SEC), JBS detailed its plan for a global restructuring in which JBS SA will contribute all of its assets except its Brazilian beef business to a new holding company named New Holdco. New Holdco will be a wholly owned subsidiary of JBS International.
JBS SA, the retained Brazilian business, will become a consolidated subsidiary of JBS Foods International but will still trade separately on Bovespa, the Brazilian stock exchange. Current shareholders of JBS SA common shares will receive one JBS Foods International share for every four JBS SA common shares held on the distribution date. The transaction is expected to be completed in the fourth quarter.